ML20212L990

Team Assessment Insp Rept 70-734/87-01 on 870112-16.No Violations Noted.Major Areas Inspected:Lessons Learned & Plant Operations,Including Procedures Control,Training, Nuclear Criticality Safety & Fire Protection

ML20212L990
Person / Time
Site:	07000734
Issue date:	03/05/1987
From:	Brock B, Andrew Hon, Pang J, Qualls P, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212L960	List: ML20212L956 ML20212L990
References
70-0734-87-01, 70-734-87-1, NUDOCS 8703110021
Download: ML20212L990 (41)

Text

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U.'S. NUCLEAR REGULATORY COMMISSION.

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REGION V 1

4 L Report No. 70-734/87-01

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Docket No.70-734 License No. SNM-696~

Safeguards Group 1

. Licensee: .GA Technologies, Inc.

P. O. Box 85608 .

San Diego, California 92138 Facility Name: Torrey Pines Mesa and.Sorrento Valley Sites Inspection at: San-Diego; California Inspection' Conducted: January 12-16, 1987 Inspectors:

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B. L. Brock, Fuel Facilities Inspector Date Signed TnO+ LBM J. F. Pang, R$iation Specialist Date Signed

[N yn - Fot2. 3/547

.A. L. Hon, Electrical Engineer Date Signed Stu1kpin. d k

• g/s/27 P. M. Qualls, Fire Protection Date Signed Approved by: ## "' " J/S/~/7 R. D. Thomas, Chief, Materials Radiation Dat'e Signed Protection Inspection and Licensing Section Summary:

Inspection on January 12-16, 1987 (Report No. 70-734/87-01)

Participants:

The assessment team included representatives from NRC Regional and headquarters ~ offices, EPA, FEMA, State of California Office of Emergency Services, State of California Department of Industrial Relations, Division of Occupational Safety and Health, and City of San Diego Office of Emergency Management.

8703110021 870306 PDR ADOCK 07000734 C PDR 6

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. Areas ~ Inspected:~ 'A special announc'ed: team assessment was conducted'using a~. -

T list of " lessons learned" for' inspection guidance. The>1ist was developed by

{NRC-inspectors following assessments of the Sequoyah Fuels Corporation:UF

' release and the Allied / Signal' Corporation incident. Theteam>assessmentkiso '

L addressed areas of.; plant operations. including procedures, control,-training,

.- nuclear criticality safety, fire protection,. system engineering, industrial A

-safety, industrial hygiene, emergency preparedness and radiological safety. ~

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-Results:- No viola'tions were identified during the team assessment. _

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TABLE OF CONTENTS -

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ISubiects -

' P_ age ,

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il. :AssessmentiTeam Members . . . .. . . . ~ '. . . ..< . ,.. . . . . . . . '.- 1! ,

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,mi.2 ' Persons Contacted ^. . . . .=. . . . . . . . . . . . . . . . . . . 1~ ,

s u A. .GA: Technologies,i I ncorporated. v . . . . . . . ... . . ... . 1 Offsite; Agencies . . . . .c.1._. ... . . . . .. . . .

- .,, B. . . . '2.

Assessment TeamLRe M ndAtions . . . . ... . . . . . . . . . . .

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L,  %, A. WrittenzProcedures'. . . . . . . . 2-J B.4 _0perator Training. ..... . . . . . ... . . .-. . . .. . . . .

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. . . . . . . . . . . . . .2 a .. C. 1 Nuclear; Criticality. Safety . . . .N . . . . . . . .. . . .. . -2 D. Fire Protection.'. . . . . . . . .:. . . . . . . . . ... . . :3 rE. " Sys tem ' Engi nee ri ng . . . . . ". . . . . . . . . . . . . . . . . . 4 e F. Industrial Safety. . . . . . . .,. . . ._. . . . . . . . . . "4 o

-G. = Industrial Hygiene . . . ? .'. . . . . . . . . . . . . . . . 'S

.:e .  ;, H. EmergencyfPreparedness . . . . . . . . . . ... . . . . . . . 5

_ I.; ; Radiological Safety. . . . . . . . .,. . . . . . . . . . . . 6 .

. a Pla'nt 0perations) Review . . . . . . . . . . . . . . . . . . _ . .

4. . 6

'A.- ~ Written Procedures .,. . . . . . ... . . . . . . . . . . . . 6 B. ~ 0perator Training. . . . . . . . . . . . . . . . . . . . . . .6

. ,,J- C. Nuclear Criticality. Safety .p. . . .a. . . .-. . . . . . . . 7-

' D. Fire: Protection. . .' ; ... . . . . . . . . .,.i. . . . . . . 13 .

E. System Engine ~eringi. .~. . . . . . . . . .. . . . . . . . . . 16 F. Industrial. Safety. . . . . ... . . . . . . . . . . . . . . . 19 G.x -Industrial Hygiene .1 . . . . . . . . . . . . . . . . - . . . 20 ,

H .' Leergency~ Preparedness . . . . . . . . . . . . . . . . . . . 21~

I. ' Radiological Safety. . . . .'. . . . . . . . . . . . . . . .

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5. Lessons'-Learhed. Items 1(NUREG-1198). . . . .. . . . . . . . . . 28 ^

_A. (Item'3.1 1.2(1) Emergency and Radiological Contingency

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1 - m Plan .~ . . . . .. ... . . . . . . . . . . . 28

• W B. ' Item 3.1.1.2(2); Independent E&RCP Audits . . . . . . . . . . 28 C. Item 3.1.2.2(1) Emergency, Response Training -~ Onsite . . . . 29

~f D. Item 3.1.2.2(2) Emergency (Type) Response Training -

Offsite. . . . . . . . . . . . . . . . . . . 30

~ E. Item 3.1.3.2(1) Exercises and Drills . . . . . . . . . . . . 30 F. Item ~3.1.3.2(2) Exercises (Type) and Drills Offsite

,- Involvement. . . . . . . . . . . . . . . . . 31 G. Item 3.1.4.2(1) Facilities and Equipment . . . . . . . . . . 31 w , H. . Item 3.1.4.2(2) Emergency-Equipment Caches . . . . . . . . . 32 r

I. ~ Item 3.1.4.2(3) Emergency Egress Equipment . . . . . . . . . 32

. J. . Item 3.1.4.2(4) Emergency Communication Systems. . . . . . . 33 L', _ K.

Item 3.2.2.2.2(1) Unified Voice for Media. . . . . . . . . . 33 i p -

- L. Item 3.2.2.2.2(5) Standardized Sampling and Preparation. . . 33

_ - M. " Item 3.3.1.2(1) Notifying Other Federal Agencies . . . . . . 34

,~' .N. . Item 3.3.2.1.2(1) Interagency Planning . . . . . . . . . . . 34

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'P. . Item 3.3.4.2 Access. Control During Emergencies . . . . . . . 35 .

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-Q. Item 4.2.2. Reporting to;the National Response Center. . . . . ,36 R. Item 6.2 Health Effects Reporting Short and Long Term.'. . 36

6. Exit Meeting. . . . . . . . . . . . . . .'. . . . . . .-. . . . . .

A.  : 0 pen Items.. . . . . . . . . . . . . . . . . ...'. . . . . . '36 B. Other Topics-' - -

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' Nuclear Regulatory Commission a'- .=1 . .

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. .-  : B. ; L'.h Br'ock,: Team Leader,iRegio'n V. . ' b,+ -

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.J.sFu Pang, Radiation Specialist, Region V.

'i 1 A.-: LhHont Ele'ctrical: Engineer,? Region V s n .P. M. Quallsp FJre Protectio'n Engineer, RegionLV

.N.'Ketzlach, Senior Scientist! Criticality Safety,*HQ-NMSS y.

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G.'L.Sjoblom, Chief,SMP,iHQ-IE; ' ,

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- Environmental' Protection Agency (EPA) * * ' '

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. ~D.LiDuncan,: Region'alRadia$ionRepr$sentative Fe'deral'EmergencyManagementAgency-(FEMA) i

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s J. D. DominguezLSupervisory Natural Hazards; Management' Specialist: ,  ;

W.lJ.EPatterson,1 Emergency Management Specialist

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.~ t ^ State of' California -'De)artment'ofJIndustrial Relations Division:of "

~ : Occupational Safety and iealth c ~

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', I. I..'Chae', Industrial Hygienist- c fS. I..Shattuck, Associate Industrial Hygienist'

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D. Nielson, Associate Safety Engineer SfiteofCalifornia-OfficeofEmergencyServices,'PreparednessDivision j . 1 ' :J. P. Steinmetz, Coordinator

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bf ' City'of San Diego - Office of' Emergency Management

.W. R.-Wolf,; Emergency Coordinator Persons Contacted

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A. -GA Technologies,:Inc. (GA-T) a

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• R.' Graves . Senior Vice President and Director

*R. N. Rademacher, Director, Human Resources a *K.'E. Asmussen, Manager, Licensing Safety and Nuclear Compliance

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

~*R..P.'Vanek, Manager, Fuel Fabrication

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• A.- L. Galli,~ Manager, Security

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*V. Malakhof, Manager, Nuclear Safety .

• L. R. Quintana,' Supervisor, Health Physics

, , *R..I. DeVelasco, Staff Engineer, Fuel Development

• R.' K. Krueger,. Supervisor, TRIGA Fuel Fabrication

l. *R. J. Bott, Industrial Safety Engineer

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t*J. M.L Brock,-Supervisor, Emergency Services e

• J. Dolan, Manager, Facilities Services .

. .W. Coleman, Manager,: Quality Systems'and Defense_ Quality Assurance

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J. J..Saurwein, Fuel Manufacturing Quality Control G. Normandy, Senior Electrical Engineer P. Niccoli, Superintendent, Facility Mainten'ance

'K. Johnson, Manager, Facility Engineering ~ '

. A. Baxter, Manager, Core Nuclear Design and Analysis .

9  : R. A.;Rucker, Manager, Statistics and Measurement Control C. Wisham, Accountant, Nuclear Materials Management

• J. M. Narvaez, Medical Coordinator T. R. Colandrea, Director Corporate QA6 L.:Adelman, Health Physics Technician S. Perelman, Health Physics Technician

8. Offsite Agencies G. Stepanof, Chief, San Diego Fire Department

-N. Goodrich, Lieutenant, San ~Diego Police Department, North Area-

. Command M. Kan, M.D. , Radiation Safety' 0fficer, Scripps Memorial Hospital P. Berkenfield,, Base Hospital Nurse Coordinator, Scripps Memorial Hospital D. Ardapple, Physical Therapy Supervisor, Scripps Memorial Hospital M. Wright, San Diego County (telephone contact by FEMA)

23. Assessment-Team ~ Recommendations A. Written Procedures Prepare standard operating pr'ocedures.for use with hazardous material work authorizations (WAs).

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!~ B. Operator' Training l

Assure.that all persons.potentially ' exposed to hazardous.

materials participate'in the Hazard Communication Training Program.

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Increase interfacing frequency with the offsite medical support.

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l. C. Nuclear Criticality Safety l

Senior management should assure members of the Criticality and Radiation Safety Committee-(CRSC) have time to perform essential CRSC functions.

Enhance the status of the CRSC members.

Assure only qualified persons perform nuclear safety analyses and reviews.

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• Assure that-nuclear-safety analysts and reviewers understand  !

-- nuclear safety criteria and SNM-696 license requirements. -)

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~. Assure'that work station criticality limit signs are correct.

- before' use'.

j Adopt a' standard work station criticality limit sign format.  !

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Prohibit the use of unsafe geometry waste containers at work stations.  ;

s 4 Clearly label special nuclear material:(SNM) vault storage .

condition exceptions; - --

Improve the distribution of the CRSC audit' reports. , )

Improve the communication between s'uccessive Managers of

. Nuclear. Safety. .

As'sure' availability of documentation supporting: work station limits and controls.

' Assure the availability and use of the' latest criticality data, standards and' guides. .

Fire Protection D.

, Provide and' assure the use of more lockers for storage of flammable. liquids.

Make modifications-as necessary to assure a reliable source of water ~for firefighting.

Upgrade Pre-Fire Plans to reflect location and type of fire

, n. suppression equipment available.

Improve the' hazardous material locator list to reflect the types and the. amounts of hazardous materials firefighters may encounter at specific locations.

Evaluate the adequacy of the size of the emergency services staff.

Evaluate the adequacy of the propylene tank storage area.

Provide signs and storage of flammable materials in accordance with applicable National Fire Protection Association (NFPA) codes.

Renew, paint, and relabel pipes that transfer hazardous materials.

Assure that safety related valves and gauges receive preventative maintenance.

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JConsider use"of,an'independe'nt ' expert"for . evaluation of the ~: ,

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, fsite fire. potential and the preventativeiand mitigating. ':. i 3 3, fm , s4 , . " .

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Consolidate scattered information'related to original designs?

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. design bases.areJno' longer available.. ,

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YAssure"reliabilityofthecriticality,alarmsystemthrough-

? s:  : surveillance and testing atLthe current level "as a~ minimum. '

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, *(* Fully 1t'est all safety features-on the/TRIGA Fuel Facility Finest "

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Furnace Control. System prior (to' operation of the system.

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lpehjodicfllytestequipmentsafetyfunctionsduringoperations-t

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(ImplementLa~ scheduled preventative / maintenance' program for: ~'

._ process equipment.

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g,juaththeQAprogramandexpanditsapplic'abilityLtothe m ,

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y. Continue ~to provide s'trong,' leadership to the plant safety C

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Consider using site area' managers on the committee to enhance .

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linemanagementinvolvementandresponpibilityforsafetyin '

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Consider various'means of grading safety performance by area.

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! [' - Considerhreal'safetyperformancewhen'assesshigperformanceof the respective ' area. manager. a. ,

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The Safety Committee should review the adequacy of inspections i' '

of the smaller' laboratories. ,

P ' Assure thatigas bottles and gas bottle carts are properly

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.Developclear;linesiofauthorityandresponsibilityffor?a

,~ystematic Safety and: Health-Management Systea.

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, Eliminate. incompatible chemical storage. -

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'Considerinstallationof'toxicgasmo.nitoYswhere-appropriate.

.. ' H. ' Emergency Prepar'dness: e

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f Consider combining the Radiation' Safety Course training

, information-in:the Health Physics computer file with the- ~

a' training information in the computer file administered'by the f' Supervisor Emergency Services to facilitate' assessing training

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'needs. The Health Physics computer file' training records

' should'also be maintained.

Consider establishing contact'with the San Diego C'ounty C

' Emergency Response Office.

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• ; Consider use' of the State of California Protective Action

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Guides (PAG)-rather than that of the EPA in the GA-T>

Radialogical Contingency Plan.

Increase interfacing fre and include a " patient"transfer quencytowith them,Scripps at twoMemorial Hospital year intervals 1

at'most, in exercises.-

• - Plan' earliest possibl'e notification of Scripps ' emorial- M

'u , Hospital whenever a decision has been made to transport a

. patient there.

. Consider consolidation of the: separate emergency plans into a set of' plans.that are cross referenced and indexed.

t Incorporate a section on hazardous materials emergencies into the plan. ,:

I Consider including a terrorist' based emergency'section, i.

Clarify the identity of the Emergency Coordinator (EC).

, Improve documentation regarding planning and execution of A

drills and exercises.

. Conduct independent audits of' plans' drills and exercises. ,

ResolveincohsistenciesbetweenGA-TplansandtheCityofSan i Diego's Radiological Response Plan.

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[Describespace'andequipmentifunctionalallocationsforthe

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iReview the.various offsite plans,for consonance rega'rd'ing the '

various< jurisdictions and their roles and responsibilities. '

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'I. ' Radiological ~S'afety

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" Assure that' continued training of health physics technicians

'will include participation in the audits that assess the

% ' adequacy of the condition.of. site radiological safety support

, ' systems. -

c.

W- Plant Operations Review R , ,

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Theassessmentte$m'$heratingintheir'areasfofexpertise' examined" '," -

various plant operations from'a health and1 safety: viewpoint. The ' -

assessment of plant 7 operations'followed the-guidance in the NRC Temporary Instruction 42600/1, Paragraph 06.02. t r

d-A. WrittenlProcedures ,

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The licensee.has'in. place basic fire prot'ection procedures governing control and storage:of flammable and combustible materials, placement and use'of fire protection equipment, personnel' response

'in the event-of a' fire and'offsite organization response. In'

, general,,.the;11censee's procedures followed standard industry ,

practices'and National Fire Protectio'n Association (NFPA) codes.

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The 110 GA-T site wide Health Physics Procedures were: reviewed ~and-updated.justthreeyears'agc. Operation procedure reviews for

.. radiological and nuclear safety have been appropriately provided. "

In the July 1986 inspection (70-734/86-06), the licensee was cited for failure to follow a chemical neutralization procedure.

. - Additionally, an open item was identified for the licensee's failure

, to have'the industrial hygienist participate'in the review of'the

, procedure prior to its approval.' -

During the current team assessment, the inspectors found the i- i licensee did not have standard operating procedures in place for use on: jobs involving hazardou's materials WAs.'. '

Recommendation

! GA-T should prepare standard operating procedures for use with hazardous material WAs.

B.. Operator Training The licensee's training program reviewed by the NRC in June of 1986 appeared to be adequate. The open item regarding retraining was appropriately corrected. To preclude recurrence the licensee

developed a program whereby WAs would be reviewed at least yearly to insure that all persons needing retraining received it. The i -

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,  ; y The currenti t'eam assessment found that the hazardous materials  ? *

'  ; training program needed improvement., In particular, some employees l

'# :had not yet been,through the Hazard Communication Training ~ Program.

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Selected review;of fir'e' prot'ection training records . indicated the

training was up-to date and appeared to-meet. standard: industry guidelinesc #

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. . . ,The assessment' team identified a need for GA-T health physics

. ' personnel to improve their" participation in. drills with the Scripps x Memorial Hospital; This increased interfacing would improve the_

.'g, . -hospital's comprehension of contamination control and y}

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1 decontamination.

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' Recommendations ,' -

.GA-T shouldlassure that all persons'potentially exposed to hazardous materials participate in the Hazard Communications Training Program. '

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GA-T. health physics personnel-shoul'd participate more

. frequently in drills with the,Scripps Memorial Hospital.

C. Nuclear Criticality Safety Criticality and Radiation Safety Committee (CRSC)-

'The.CRSC performs a necessary function and is depended upon to

- ensure the radiological and criticality safety of the various experiments, installations and procedures. This:is especially.

2 important to complement the capability of the small nuclear safety fstaff. The adequacy c.f the scientific review depends on getting fully qualified reviewers with broad experience in the various disciplines on the committee.

Recommendations Senior GA-T management should cjive due attention to ensuring -

the continuing effectiveness of this essential function, so that its members, which are drawn from various line

! organizations, will be able to give the necessary time to the review functions they perform.

e GA-T should enhance the status of the CRSC members through appropriate recognition of the committee's role.

I A tour was made of the areas covered by the SNM-696 license. These included the TRIGA and HTGR fuel fabrication facilities, the R&D facilities in which.the principal process steps for the North

Warning System test fuel elements were performed, the Hot Cell j Facility, and the Liquid Waste Treatment Facility. None of the

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• - "Alloperatbns:wereidentifiedwithworkand) storage'st'tionilimit a (signs;~and: procedures'for each step of the operation were available- ,

.to the' operators.< Several; poor practices;were noted and are u 7' ~[;N v addressed :in ;the :following ' sections. - A _R

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, (,The' process ~forapprovalofprocedureswasreviewedand' .. <-

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<s v , appeared to be acceptable. - However, a , spot check- of the . .

' application of,the process identified several items that should-be followed uppin' subsequent inspections. ;'It appeared that thel ' j x :first independent reviewers may not;have met the required a Li

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c'i . minimum l qualification to perform the review function. The: ., -

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J qualifications.of:the independent reviewers.will be' assessed in-the subsequent' inspection (87-01-01). The' assessment team'

, 'inspectorfoundLtheGA-Tnuclear. safety' evaluation'ofthefuel y

, blending."10-Way Splitter" to be.nonconservative'though it had , ~ l 1W 1

~been'through the licensee's review and' approval process. The: a 'i!

following assumptions made in the evaluation.and the apparent-

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agreement by both-independent _ reviewers ap ~ ,

7 .lnonconservative forethe following reasons

pear to be J

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, ' a. Water was. assumed to have no. greater effect:on= neutron reflection than concrete.1

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10 cm of water" was assumed to be equivalent.to that of an mu u - b.

,, infinite water reflector. ,

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c. Although the height of each of the 10-sample collectors is 8 inches,Jit was, assumed they could be filled to a height ^

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d. Thettop$of the assembly was assumed to be bare (apparently .

J no. consideration was given to reflectors 'in the vicinity

.. of the. equipment). 'The license requires full-reflection N< "" .

be assumed unless' the reflectors'can be specifically  :

L 14 - T

. excluded.- As'airesult of.the meeting, the CRSC 1

~

criticality safety reviewer requested the GA-T nuclear 1

, safety group perform additional analyses. Although the h

safety of the equipment remains in doubt, based on the c above, GA-T had earlier determined the equipment'would not 3

1 be required. The NRC~ reviewer, however, emphasized the b .importance of "outside of ~ reactor" experience needed by

" the reviewers to perform an' appropriate nuclear safety h

review.' ,

. s ,

L- Recommendations

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GA-T assere that persons performing independent nuclear L

safety analysis and reviews meet the qualifications of NRC

, license SNM-696.

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GAk T assure that' persons' in nuclear criticality safety

. ' analyses maintain knowledge of up-to-date nuclear criticality safety criteria and the technical requirements of the Nuclear. Safety section of license SNM-696.

'(2) Nuclear Safety Con'trols '

, _ A reviewfof the adequacy, maintenance, and-surveillance of the

. nuclear safety controls was made by the team inspector. He-concluded that WAs are kept current, documents are controlled, out-dated WAs are removed from circulation, and procedures are'

- available to the workers. Manufacturing, safety, licensing, and materials control personnel are made aware'.of WA' changes in

'a timely manner.'

At TRIGA Work Station 14,"the limit sign allows the handling of one " meat" with a maximum of 1.0 kg U-235, including chips, at the station. Since the meat =may contain as little as 10 gm

. U-235,~.the sign would indicate 990 gm U-235 in the form of chips could be at the station. The WA restricts the quantity of U-235 at the-station in the form of chips to 350 gm. In addition, there was a 5 gallon bucket'for plastic shoe covers at the station. The' bucket and 990 gm U-235 in the form of chips plus water ~could possibly be made critical. Several other machining station signs were similarly misleading. The licensee corrected the signs and removed the 5 gallon bucket the same day of the inspector's observation.

The end section of shelves in'the SNM storage vault (next to the concrete wall farthest from the entry door) was used for non-SNM materials. Although the containers were of a different size than those containing SNM and were labelled, it is good practice to identify this section of shelves with a sign limiting the use of the shelves to non-SNM materials. In addition, it was indicated that 55 gallon drums containing SNM are stored periodically between this section of shelves and the concrete wall. Since this is only authorized when the adjacent section of shelves contain no SNM, the sign limiting the use of' the shelves to non-SNM materials would improve the administrative nuclear criticality' safety controls for the storage of the 55 gallon. drums.

Several work station limit signs were noted in the SV-A area that did not conform to the standard formal signs used at

practically all work stations. Station A17-28 (Inert Box, Miscellaneous) contained a limit sign th'ta was handwritten (black ink on yellow background). A similar limit sign was observed at' Station F4-3. It was recommended that use of such nonstandard signs be reviewed. If their use cannot be justified, they should be replaced by the standard type sign.

. '+ _-

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, Recommendations j -

GA-T should require that. nuclear safety review all work . ,

station: criticality ;1imit signs for conformance with the -

criterion in the nuclear safety' analysis and in the-WA

'before they are instialled.

+

4 -

Workfstationcriticalitylimit'signslhbuldbeof-standardized format, color, and print' size. .

' GA-T should proh'ibit the use of waste containers-of unsafes geometry at work stations. -

GA-T should label SNM storage' vault shelves to clearly-

~ indica.e when SNM shelf storage locations or aisle storage-locations are precluded from.use'for SNM because.~of.

adjacent area storage location SNM contentse -

, _ (3) Audits and Inspections The routine inspections by the health physics techni.cian, several-quarterly and special inspections by the Manager,

' Nuclear Safety, and annual audits made by the CRSC were reviewed. The health physics technician makes'the routine-nuclear safety-inspections. If he finds an item the nuclear safety of which he questions or it is in: violation of nuclear criticality') safety deficiency limits

, he fills out(has a " potential a special form indicating nuclear safety his' findings and reports it to the Manager, Nuclear Safety, for action and to the Manager, Health Physics.

Besides the quarterly inspections required by the license, the Manager, Nuclear Safety, makes special inspections before'a new process step is to be implemented and at other times he deems necessary. All inspection reports by the Manager, Nuclear Safety, are addressed to the Manager, Licensing, Safety, and Nuclear Compliance. A special inspection made on November 12, 1986, is an example of the need for inspecting new operations after approval of the WA but prior.to implementation. During-this particular inspection, it was found the boats planned for a low temperature furnace operation were different from those of a high temperature furnace operation (contrary to that assumed in the nuclear criticality safety analysis). . A new analysis was made modelled with the actual furnace designs planned and the WA corrected reflecting the safe operating limits for the furnaces. The need for also checking the work station limit signs prior to start of a new operation was discussed earlier.

The audits performed by the CRSC during the past couple of years were reviewed. The audit report is addressed to the responsible vice president with copies generally sent to the cognizant area manager, Managers of Licensing, Nuclear Safety, Health Physics, and members of the CRSC. The audits appear to

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be Lthorough, idocumented,i recommended - a'ction L taken, .and _

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-follow-ups.nade.of correctioniaction taken.n It is recommended-

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s fthat greater uniformitylbe made in the' distribution'of the~CRSC x

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Copies of only+some of them appear to be sent '

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• to'all' auditmembers reports 3'of the CRSC. -The~ Manager, Nuclear Safety, is on _

. ; distribution fo'r only_some of them. The s&me.is true for the

' LManager, Health Physics. - _

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f , g Recommendation' ~ .

e - GA T_should; improve.the distribution'of~the CRSC audit' reports;

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, .(4')-DocumentationofNuclearSafetYAnalyses s . # , .

-During an .earli_er ' site visit (June 14-18,1982), the' dumping of

waste solution in the dump sink in the Building 37 area was reviewed. Since the operation ~ involved the intentional transfer'of U-235 solution from a safe geometry vessel to'a^

non-safe geometry vessel,-a review of the nuclear safety.

analysis (evaluation) for-the operation was requested. Since a documented evaluation could not be found, it was recommended that an analysis be mace, documented, and retained for at least 6 months after the WA has been terminated. GA-T management concurred in-the desirability of having such an analysis I , available and made a commitment to perform the analysis,.

,, document it, and retain'it. The need for such documentation for each operation is apparent and good practice.- The license i renewal application was modified to incorporate the retention requirements. The renewed-license requires " Work Authorization Records, including supporting criticality analysis shall be.

., retained for'at least 6. months following the, expiration date of s , the authorization." During this assessment, a request was made ,

.,'~ to see the supporting criticality analysis. Since the 1982 site visit, an index of all; analyses has been prepared. The requested analysis could not be located from the index based on

.the titles assigned. The present_ Manager, Nuclear-Safety,

[ contacted one of.the former Managers, Nuclear Safety, who had n knowledge of the' operation. The latter suggested the heading in the index under which the analysis could be found. The licensee is searching for the analysis and plans to have it

'available for review by the Region V Fuel Facility Inspector

~

L p .during the next inspection (87-01-02).

r' During the assessment,.it became apparent the present Manager, l

Nuclear Safety, makes a distinction between a nuclear safety analysis and'an evaluation. To him,. the former means a

.. computation analysis; the latter, an " analysis" based on a

! previously approved one, the use of approved nuclear i criticality safety tables, or' validated documentation. It is L only the former that he documents. Good practices include the documentation of all nuclear criticality safety analyses used, which includes evaluations made. ANSI /ANS-8.19-1984,

" Administrative Practices for Nuclear Criticality Safety" l.

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L(Section18.2)? states;that "the nuclear criticality'safet91 ',

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% evaluation shall. determine:and explicitly identify the' s

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controlled ~ parameters and their' associated limits upon which:

+ 7e ' , , nuclear] criticality. safety depends,"7and.(Section 8.3)1"the -

' nuclear. criticality safety evaluation shall be documented with-sufficient detail,; clarity, .'and lack ofJambiguity to allow J

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independentjudgementiof:results.,"~

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Recommendations.

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• 1 9 ' GA-T-should' assure that; communications bitween successive ' *

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Managers of; Nuclear? Safety is improved so that.there isLa ^

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f etterb understanding of license requirements and; good , o e >

. nuclear. criticality. safety. practices, y a ,.

" " l * , _ ~GA-Tshouldagain*redewapprovedoperationsandbesure

'there'is ade~quate documentation to support work station

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limits and controls. '

_ . . . . .. e GA.-T'should review'the nuclear criticality safety standards, guides, and developments to' ensure-that good

, practices are followed and the latest: criticality data

.s utilized in. establishing safe ~ operating limits.

;; . ?- '

1* The'Ma' nager,: Nuclear Safet'y,'should have all applicable Y cs tandardscand guides readily'available.

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(5) : Accident Scenarios

. .- A range 'of postulated ac'c idents has been analyzed by the licensee. The.one with the' greatest potential'offsite c 4 radiological consequences but lowest probability is a criticality in_the Fuel. Fabrication Facility (Building 37) at

'. the process liquid dumping site (see discussion above). The liquid dump room is designed to mitigate the results of a . _

. criticality! accident and has 24-inch thick concrete walls and a 16-inch thick concrete ceiling so that the expected dose'to

, . +

anyene at the site boundary for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following the accident

would be 0.27 rem whole body, 0.26. rem thyroid, 0.015 rem bone,

i. .and 0.023 rem lung dose. These doses are well within the PAG

!. .and EPA limits (1 rem whole body, 5 rem thy'roid, and 3 rem' other critical organs).

(6) GA-T Planned Response to Criticality Accidents The Chairman of the CRSC. reports to the EC at the scene of the a' emergency. Other members of the CRSC report to the Emergency Support Center, pending instructions from the Chairman. The Manager, Nuclear Safety, also reports to the EC at the scene ~of p the emergency, if the emergency involves SNM. This technical t group, together with those from Health Physics who also report i to the Emergency Coordinator, provides the necessary experience L ,

to cope with a criticality accident and restore the facility to j normal operations.

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M N~ ;The; inspection team madetan assessment-of the licensee's t L 'v o

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.s implementation of. fire protection > features and programs in order to

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ascertain'a better. understanding'of the adequacy of the level. oft ,

14 p ; - c fire protection provided.for facilities"and plant ~ operations.' This

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' f .if,' ' assessment was made~ on a ra.ndom sampling basis. Therefore, the -

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a results'are'not? intended"to~ convey conclusions about aspects of the- ~

C" <  : facilities fire protection.that;we_re not part of this~ assessment.

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-The results for areas assessed are assfollows:t

,p., c (1)J Fire ~ Prevention Program o  : A, o ~ _

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< Fire Prevention Procedures- "

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e The licensee'has in' place' basic' fire protection procedures l

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governing control and storage _of flammable and combustible

. materials, placement.and 'use of. fire protection equipment, personnel ^ response 1n the event of a fire and offsite

. organization response. - In. general, the licensee's procedures.

followed standard industry practices and NFPA codes. No significant weaknesses were identified in the licensee's

, / -

procedure. One observed weakness in procedure implementation c appeared ~to be in the area ~of control of flammable liquids.

' ~ -

' Flammable: liquids;'not in use, in non-safety containers were

, observed in several of~the licensee's' facilities.-

' Recommendation

-GA-T should provide more flammable liquids lockers and

' more stringently require employees to keep flammable 3 , ' liquids in these lockers.

(2)' Fire Suppression Equipment The' inspectors observed' fire suppression equipment in areas.

e throughout the licensee's facilities. The equipment. appeared

to be well maintained and easily accessible. No overdue L calibration tags were identified. The inspector examined the r - maintenance requirements and records for the fire suppression l- equipment. ~ The maintenance'and' inspection requirements were in accordance with manufacturer recommendations and NFPA codes.

l~

I Records indicated that maintenance had been accomplished in

[ ,' accordance with'the specified. requirements.

, .The inspector also examined the drawings for the main fire water loop. It appeared that a single line break in the loop 4 at three different locations would make water unavailable to fight fires in areas where fuel is processed. In addition, licensee personnel indicated that there had been about 14 line

breaks since 1980 and the supply line has been in service about 30 years. The licensee's compensatory measure for a line break

< is'to string 2\" fire hose to supply ~the affected areas. This.

g' amount of water would not be adequate to supply the 10

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(3):. Training ,

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-' 'Thefinspector reviewed selected training records of. licensee

. xpersonnel. assigned to.respondiin the. event of a fire. The training was1up-to-date and the training appeared.to meet '

' standard industry guidelines.

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'(4) Pre-Fire Plans +

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r T The. inspector reviewedithe Pre-Fire Plans kept by the.1icensee.

__ , 'and a copy of'the plans provided to the local fire department.

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The licensee's_ plans did not-in all cases include locations of ' '

< .' , y fire suppression equipmento In addition, the licensee's plans did not include a detailed list of hazards expected from fires-

.in' specific buildings. -Due to the large variety and various-

locations in'which hazardous chemicals are?used at the site,

. licensee personnel stated that.they were attemptingLto provide

. this data by using a ' computer. lThis ' system is not yet fully operational.: The plans provided to the' local. fire department

+ did not:contain as much:informatiun.as the' plans kept by the

. l licensee. , Licensee ' personnel l stated-that this was a fire 1

4

. department instruction because'they had too many nearby i .. - industrial. facilities toikeep several volumes for each.

N '

Licensee emergency response personnel meet the responding fire p department'at the scene of a fire and instruct the responding i unit as to location and types of< hazards that are: expected to -

be-encountered. To keep current, the_ licensee requires his j emergency response personnel ^to tour each facility onsite once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

,- , . Recommendation b GA-T should upgrade the Pre-Fire Plans to include location and type of-suppression equipment.available,

[ i 4 -' GA-T should continue with efforts to computerize location, amounts,'and types of hazardous materials to which fire .

fighters may be exposed.

. .t.

F c' (5) Insurance Audits

?

-' The inspector reviewed several of the most recent insurance i

. fire protection audits to determine the licensee's l-responsiveness. In general, the licensee closely reviews the p -s i-I+ t t

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15 audits and takes prompt corrective actions on identified deficiencies.

(6) Fire Prevention / Protection Staff The licensee has available.a supervisor and four technicians to provide services on a 24-hour. basis including holidays and allowing for time off and vacations. Their duties include:

(1) site fire prevention, (2) hazardous material monitoring and control, (3) fire systems maintenance and testing, (4) daily tours of all facilities, (5) conducting emergency response training, and (6) responding to site emergencies.

Recommendation -

The size and complexity of the site and the quantity of work warrant the licensee's consideration of increasing the emergency services staff.

(7) Facility Tours The inspector noted two potential problem areas during facility tours:

a. West of Building 37 is a large (20,000 gallon) propylene storage tank. The pilot valve operated deluge system to the tank is supplied by only one fire line thus a single failure would make it. inoperable. In addition, at the time of the tour, the licensee had about 10, 55 gallon drums of isopropyl alcohol, a stack of materials in styrofoam containers, and a couple of trash dumpsters which were open and full of plastic pipe shavings stored within about 20 feet of the tank. Further, a propane tank and a trailer of acetylene bottles (normally about 170 bottles when the plant is operating) are also present in the area. A major fire in this installation could result in extensive damage to Building 39, pilot plant, and Building 37, production plant, because of their close proximity.

b. Near the laboratories, the licensee had stored a large quantity of chlorine and some tungsten hexaflouride gases (oxidizers) with hydrogen gas (flammable). This storage arrangement is not in accordance with NFPA 43 C and no signs.were posted identifying the hazards. (87-01-03)

In the above cases, the inspectors thought it unlikely that a problem would result in any offsite release of radioactive materials.

The inspectors also observed rusted hazardous material transfer lines with faded labels; valves and gauges that apparently would benefit from preventative maintenance; tanks for which grounding improvement was needed; and an inventory of hazardous

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.- materials that.should 'be' reduced'in light of current and near.

4 term operations. It,also appeared the licensee could benefit from"an independent evaluation of the fire ~ potential and the adequacy of the preventative measuressin place.

e Recommendations GA-T should ' evaluate; storage areas around the propylene tank and move trash dumpsters to a different location. ,

~GA-T should provide signs and storage for oxidizing-materials and flammable materials in accordance with applicable NFPA. codes.

GA-T should renew, paint, and relabel hazardous material transfer-pipes.. .

GA-T should assure'that safety-related valves and Cauces receive appropriate preventative maintenance.

GA-T should assure that tanks are properly grounded.

GA-T should consider reducing the inventory of hazardous materials for which little need exists currently or in the near term.

GA-T should give consideration to an independent, expert evaluation of the fire potential and the preventative methods in place.

(8) Overall' Conclusion in Fire Protection The licensee appears to have a generally effective program in this area. It appeared unlikely to the fire protection inspector that at this time a fire would result in any offsite release of radioactive materials.

E. System Engineering The objective of this review is to assess the safety adequacy of the licensee's equipment from design through operation phases.

(1) Safety Analysis and Design Base The licensee's accident analysis is described in Section 7 of the Demonstration volume of the SNM-696 license. The licensee analyzed for radiological releases from accidents. These accidents could result from ordinary industrial hazards such as fire and explosion, natural disturbances such as earthquake, windstorm and flood, and, accidental criticality, though they were not considered to be credible. The licensee determined that for the worse case credible accident, the release to individuals in unrestricted areas results in annual radiation doses below those set forth in 10 CFR Part 20. The licensee

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r ae considered that no structural damage will' occur to the effluent control system due to natural disturbances because the structures housing the systems were constructed in accordance with applicable local building codes. ~In the analysis of P possible fire / explosion hazards, the licensee considered several fuel production processes that result in off gases

. .containing carbon monoxide and hydrogen. Afterburners and dilution were used to minimize fire and explosive hazards.

During the inspection, the inspector noted certain safety features were built into the process system such as the combustible gas monitor for the dry coater and interlocks on the DESMA high pressure press. However, the licensee was unable to present documentation for the safety analysis performed on each step of the process to identify operation and off-normal conditions as bases for designing the equipment to prevent and mitigate consequences of potential accidents.

Records of the original design philosophy and even the as-built drawings were no longer readily available. The safety analysis

- provides the bases to assure that an adequate margin of safety was provided by the design. Furthermore; it also provides the criteria to assure later modifications will not result in-reduced safety margins or operation of the equipment under conditions not previously analyzed.

Recommendations The licensee should' consolidate the scattered information related to the original design or perform analysis where the original safety analysis and design bases are no longer available.

The up-to-date as-built drawings should also be maintained for each process system.

(2) Engineered Safety Features

a. Criticality Alarm System and Associated Power Supply System The licensee's criticality alarm system used two radiation monitors for each area' monitored. This recent modification uses a two-out-of-two coincidence logic to actuate the horn, thus significantly reducing spurious alarms. The monitor system, except for the Klaxon horns, is. powered by physically separated. redundant battery groups. The battery chargers are powered by offsite AC

. with a single diesel generator. *The Klaxon horns are powered by offsite AC or the single diesel generator without automatic switching. Since the only redundant

~

part of the system is the independent battery groups, the present' configuration is susceptible to single failure.

For example, the Klaxon horns will be inoperable if the single diesel generator fails after a loss of offsite power.

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?The inspector reviewed the periodic surveillance-and-

>' ~ . fealibration. procedures:and records for the criticality s E i(

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', 'al_ arm.'systemi batteries arid:the diesel tgenerator. : They" '

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appeared to be satisfactory.1

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t-4 e1 l Sincel the 'systsm' is' susceptible to ' single' failure, ' ,

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'A .thetlicensee should' assure its reliability through surveillance ~and testing; as a minimum, at the w- .

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Built-in 4 Safety' Featsres_ Oper' ability.. ,

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One"of the built-irNs$fetkfeaturesl evaluated was- the -

, TRIGA Fuel Facilities *F,ines< Furnace ControK System. The-inspector;notedLfro.1 the documentation'provided by the-J licensee'and . interviews withl licensee' personnel,=that one of:the redu'ndant safety scram switches was by passed for' ,

• ~

no apparent reason ~for an1 unknown period:of; time', probably

since,the facil.ity was constructed. JAnother failure was a

': relay > contact: welded,to form a permanently closed circuit.

V The licensee concluded from.the evaluation that a'

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preventive maintbnance program was necessary and all' < ,,

modifications 7should be reviewed and approved prior to x their implementation., , ,

7 Recommendations

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5. .

.GA-T should ful.ly test all safety featurasi 1.e. ,

each of'the scram channels, prior to;the operation of ~

the spstem.

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t, t GA-T should' periodically' test safety functions during -

operations to assure-their readiness.

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c. .EmergencyCoolingWater-Systhm l ,

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To prevent over-t wperature' damage to the process equipment in Building 37 upon, loss of power to the cooling -

water circulating pt.mp, the licensee installed a backup

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generatorapowered by a: propane. gas engine. The generator.

L -

was tested periodkally.to assure its operability.

Provision was also made to use city water if total loss of circulating water occurred. The valve to isolate the city water supply was; administrative 1y. controlled to assure

the availability of backup water. A tag on the valve 3

directed personnel to obtain the facility manager's approval'before operating. The system appeared to.be F' adequate for the intended purpose, though it is not a j- redundant system.

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g . d. LMaintenance y a ,

The licensee's maintenance program for the ocess F ,

equipment was mostly corrective maintenance when component.

failure is found or on an as-needed. basis during ioperations. A pre planned periodic preventive maintenance program was not implemented except for the criticality:

alarm system and the' emergency generators.

~ Recommendation-GA-T should implement a scheduled preventative maintenanco program in order to: assure the-operability of safety features, maintain the integrity of the process system, and prevent' degradations'which could lead to catastrophic failure during operations.

(2). Quality Assurance (QA) ,

The licensee QA program _is described'in the QA Manual which'

~

conforms with 10 CFR 50, Appendix B --QA Criteria for Nuclear Power Plants and Fuel Reprocessing, Plants. The independent Corporate QA organization developed the-QA manual and performs selected audits on the fuel. production organization. The Quality Control-organization ~within_the _ fuel production-organization performs production' process quality control and calibration of process instruments to-assure the fuel produced meets'the specifications. s The inspector reviewed samples of audits performed by the Corporate QA organization during 1986. -It appeared that both the' audit-and corrective actions were adequate for the area audited. However, the licensee's QA program applies mostly to the product. The designi construction, and operation of the process. equipment were not addressed by the QA program. For example, the by passed safety feature on the Fines Furance

' Control System would have been detected if the QA program was i applied to the process equipment.

~

Recommendation L GA-T should evaluate its QA program and expand its

! applicability to the process equipment, where appropriate.

F. Industrial Safety The plant safety committee is comprised of representatives from each

, of the major plant site areas and is headed by a chairman who presides for a one year period. There are subcommittees in each of the plant site areas. In this way, GA-T endeavors to instill in

! line management the improvement of industrial safety through local

, area inspections. It was pointed out that many of the site area representatives were lower level, though interested, personnel. The i

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safety committee and the area subcommittees are supported by the , , -V

'small professional'stafft ,

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eviewofthel'icensee'sI'ndustrialSafetyProgram. i noted the licensee's-inventory listing of. hazardous materials'needed'

1. J- simprovement with regard to the: quantity;and location of the: ...

c- ' . hazardous materials on site.' An; improved listing would,be-usefulyint -

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. assuring > emergency response personnel would'not be caught unaware by"

..the. hazardous materials that may be encountered during an emergency.

LWhile: touring the, site, the. inspectors noted gas-bottle. carts in 5three areas were not properly secured. SThe carts, 1arge square'. ,

steel plates with wheels,-were nat immobilized by wheel locks:ori s S ,

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.- -Recommendations i N .

GA-T should continue to' emphasize strong leadership in the Lsenior managers selected to chair the plant. safety committee.

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+ 4 GA-T should consider req'uiring the area member of the committee e to be the senior manager of each area, to further enhance the.

line' managers involvement.in and responsibility for al.1. aspects- e of' safety in the respective facility. These. managers-should.

. also chair <the re'spective subcommittees.

GA-Tlshould consider several means to grade safety performance in'each area. 'For. example, trends-in inspection findings and corrections,-or in numbers of incidents.

.a. _

GA-T'sh'ould.also consider usi'ng area safety performance as one element in assessing the perfomance of the respective-managers

• It is su g m ted that.the committee review the adequacy of the

~

inspections, .nat'areibeing conducted in the many"small laboratories becauseJof the' numerous and varied nature of the investigatorsiand experiments and,the many diffe_ rent chemicals, gases, and types of, equipment used in these laboratories.

'GA-T sh'ould assure h'at gas bottles and gas bott'le carts are properly, immobilized. -

7 G. IndustrialJHygiene' lb There 3sta'need for. continuous management review of the adequacy of L

the health and safety. staff,4 due.to;its current'small size, and the l' .

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. extensive facilities requiring coverage, in spite of the low scale H of current operations. ?The staff area where losses of key personnel p result in the' loss of expertise ~can be.particularly troublesome and f

this continue ~s to occur, for example, with the departure of the-industrial hygienist associated with.the incinerator project. An effort was currently; underway to fill the vacancy, initially a

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l part-time position',. as 'a full-time position. The inspectors noted E

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that Safety and Health ~ responsibilities were shared among'various

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managers somewhat obscuring clear lines of authority. The inspectors also noted that the licensee needed to assure.that

-incompatible chemical storag; did not exist. Further, the inspectors identified a need for an alarm system to alert employees -

to releases of toxic gases used onsite. The inspectors also identified that some hazardous materials WAs did not have associated procedures for workers to safely conduct the operations that required use of hazardous materials. Methyltrichloroxylene is used-hg at the site and it appears the preparation of a standard operating procedure for its use could improve its control and the reduction of -

spills (it reacts with water to form hcl).

Recommendations

,E The licensee should develop clear lines of authority and responsibility for a systematic Safety and Health Management gg System. I1 The licensee should fill the recently vacated Industrial w Hygienist position.  :-

E The licensee should conduct a careful review to assure that g

incom'patible chemicals are not comingled in storage. g The licensee should give consideration to the installation of k alarm systems where various toxic gases are in use. p na-The licensee was required by the State of California, under separate. 4 cover, to provide appropriate labels on hazardous material 'a containers (squeeze bottles and containers up to 5 gallon size) @

noted in several locations without appropriate hazard warning a labels. The licensee further.was required to assure that all  %

affected employees received the required Hazard Communications g Training. The license was also required to improve the storage of -a Self Contained Breathing Apparatus face masks. The need for 3 improved handling of chlorine gas was also identified formally to 5-the licensee. -?_

sy H. Emergency Preparedness

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The EPA assessment area included both Emergency Response and Environmental Monitoring. Review of emergency response planning q

e included discussions with GA-T emergency personnel, the City of San ~Jr Diego Fire and Police Departments and the_Scripps Memorial Hospital.  ;: .

It was apparent from the discussions that a considerable effort had it been made to establish plans and to provide training to implement the' plans. The personnel currently involved are enthusiastic and A*

feel that they have the needed administrative support. Because of the very different separate facilities on the GA-T site, the GA-T plan is similar to that of an industrial park, i.e., no one person is in charge of the response at every site. g GA-T has established requirements for emergency personnel in various j capacities. Many of these require formal course completion and g B

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m, '. annualirefresher' training. At present,.the different course-

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fcompletions~relatedto'thelpersonnelauthorizationsarenot ,

~ ~ maintained..in~oneffile.,;A review of" names selected at random

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sindicated a*need;to fiaprove the, documentation of course completions. .

=Additionallyn a smallistaff resultslin:a-limited; number of

_ presentations each year;:and the normal employee

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or sick 41eav~eipresentia scheduling; problem. A 1

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w: ,LGA-T'should give: consideration to combining the Radiation ~ b

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Safety Course: records in the Health Physics computer file with 4 the'tra'ining information in the computer file maintained by the Emergency; Services Supervisor.to facilitate. evaluating' training, s needs N The training recordsLin the: Health Physics computer a fileLshould also be maintained'(See Section 5.C.):

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• Thelicenseehasdevelopeda~humberofbaseand[ supplemental.

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' emergency-plan. documents. . These~ documents are under separate

. . cover las; designated by the licensee to accommodate;the needs'of.

'the various managers.;~However, there~is little or no cross

.- reference as;to their' relationship.and use. Minimally, this

?., . portfolio of planning documents,. including base plans, ~

contingency. plans,: procedures,'< letters of agreement,'etc. ,

. should be indexed in accordance'with specific purpose'and i S

. relationship under one master. list. This 1.ist*,.as" appropriate,

.could then be used as.a reference in the various plan elements.

LIn addition,: the physical consolidation of theseidocuments into

~

sets also. appears desirable. These' sets could be issued to key staff and/or-placed in strategic: locations.

~

The incorporation of an amplified section on hazardoes materials emergencies'into present plans is needed. The:,e E

added elements.should be. designed to address compliance with applicable regulations. .

g The~ incorporation of a section addressing terrorist-based emergencies.Lis needede Clarification of the identit'y o'f the Emergency Coordinator (EC) s

.is.needed. Th'e EC is described'as " Manager, Compliance

, , ~ Control"-in Section' 4.-l.6 of the GA-T Radiological Contingency b '- as Plan. dn' the GA-T Emergency Plan, the EC is referenced as

&' " Manager, Health Physics and Safety. Services" under Section

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1.1.4. .

\- Documentation:of,offsite organization plans and preparedness.

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. activities including visits, tours, meetings, training, inspectio'ns, drills and exercises would be of value to the y licensee and to other parties interested in overall j: .- preparations.

• ' The periodic schedulihg of formal tr51ning and exercises involving-offsite organizations is desirable.

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f 'y e a Security: Station No. 1,:and a facility for.us'e by the media. . Space and equipment in addition to Station lishould be described.by' functional use, i.e.,.

command and control,^ media,'etc.,1and incorporated into subsequent plan revisions.

4 The existence of the various local resources, systems, and arrangements to respond to offsite radiological and> toxic chemical emergencies that may originate at the GA-T plant are evident. However,.the various offsite plans should be' reviewed for consonance regarding the jurisdiction of respective roles and responsibilities.

The review should include the delineation of the role of the State in. emergencies that might involve protective actions resulting from ingestion pathways. What is the role of~the

Interdiction Committee or the procedure's inv'olved in the re-entry of evacuees at this site? In addition,-the State policy regarding the administration of potassium iodine (KI) to

. emergency. workers and others should be-addressed. This factor e is especially important since the County Health Officer is usually tasked with the responsibility to administer-KI.

Finally, there should be a widescope cooperative effort'to coordinate offsite public information and media release strategies and procedures among the local, State and Federal agencies. All of these matters should then be referenced in

- the offsite plans.

Because.of the licensee's ongoing planning and preparedness I activities with the offsite jurisdictions, it would appear that GA-T could facilitate an appropriate forum for the City'and l-County to address these matters. Perhaps a committee that l' would include a representative from each of the agencies ,

involved might be formed. Such an integrated aoproach would L probably ensure the largest measure of overall cohesiveness, consistency and effectiveness in response planning and preparedn,ess.

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4 1(1);?Sa'n Diego City Fire and Police Departments: ,

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'TheiSan'D'fego City. Fire and Police Departments demonstrated'a;

- < very workable, coordinated plan for emergency activities. Both

, .Departaents have'a continuing familiarization program with-GA-T. This activity-includes tours and inspect. ions of the plant by the City's Police and Fire Departments.' Participants

-have included firefighters and hazardous materials specialists involved in Fire Prevention Bureau and pre-fire' planning m matters ~and security-oriented meetings and tours by Police SWATL

,' personnel. ~ Additional interaction is also' accomplished by:

Fire Department bi-6nnual radiological ~ monitoring checks; City.

officials and Fire Department staff taking courses at GA-T;,and

( actual. emergency activity during and following. incidents and

. accidents at:the; plant. The City opeiates a special' vehicle

equipped to as_sist in hazardous material; emergencies. The' vehicle,; funded through Superfund monies, is manned by a. .

~ specially; trained Emerge.ncy Response Team. -It is. located in La

-Jolla in close proximity to.the plant. The _ vehicle. contains .a :

library of files-including emergency plans and inventories of-hazardous. materials and chemicals at specific locations. 'The

. County of' San Diego~has'a'similar vehicle for'usesin the .

unincorporated areastof the(County.

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There,is, good rapport between GA-T plant.and City: emergency

. staffs. A police radio has been provided and is placed in the '

Sorrento Valley area facilities. The Fire Department indicated

~

they depend on-the GA-T Emergency! Services' personnel to:: provide any necessary, specific. problem information. The Fire Department.has'the-lead for'onsite coordination dealing with radiological, hazardo'us material and bomb emergencies --

includingfresponsibility for decisions to evacuate within its-City limits. The County, supports the' City in radiological-incident control cleanup'and disposal. :A' representative of the

' County,' ?will actn as a coordinator for~ the~ City's Fire o Department Command'Po~st Comma'nder in notification of and 3 L coordination of County, State, Federal" agencies and public information" according to the, City's Radiological Response T

. Plan. Emergency broadcast stations are under the control of-

,. the Cou'nty of San Diego.

- i The City,is a member of the Unified. Disaster Council which

, meets quarterly 'and is chaired by the County's Chief J Administrator. ' The-Council includes one representative from

.each city and provides a forum for Region-wide emergency 3 management coordination. Currently, the City and-County are in the process of revising their emergency plans. Consistency in 1 -

San Diego County / Cities emergency plans is provided, in part, through the use of a Unified Response Plan and a Multi-Hazard Planning Project. The City provided FEMA with copies'of its present Radiological Response Plan and Hazardous and Toxic

( Materials Annex (draft).

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'3 ' m January;13, 1987, meetingas a result of.a communication <

. problem. However, this did not pose a.1arge-problem to.the

, a 3

assessment since the County 1of San Diego is one.of the seven

'offsite jurisdictions.that routinely participate,in the offsite.

- ^ . . ' emergency. response' planning and exercising program for the San: .

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S 0nofre Nuclear Generating Station. They have successfully._ >

demonstrated implementation of- their plan and their ability ~ to J

l precluded protect the~the public's. health effort and welfare.the The County's; absence w - - team's' to evaluate coordination and

< positively identify the alert and notification of specific individuals,' however, the' organization'is in place and the-

. expertise to evalu' ate, and implement actions is present. .

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, , (2) Scripps' Memorial Hospital y% - '.

ScrippsMemorialHos'pitalMa,s~de'velopedspecificproceduresan'd

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facilities to care'for,a contaminated patient. However,.the.

inspector's' review of their faciliti

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several: things '(emergency ' cache .acce.es-and ss,ccontamination ' equipment ind control,

- ~ etc.'):thaticould be'1mproved V Periodic visits by GA-T. health

' physics; personnel andijoint participation in drills could-

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w' other needs and provide for 'a better training probably:

effort. .Necessary identify.fsupplies'that'areprobablyroutinely _

available'at GA-T_s'uch as; plastic backed absorbent paper to'

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prevent the spread of. contamination'should be available'to the hospitalt . At present, the~ hospital personnel are very

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, Jenthusiastic'and have taken.and provided training.- But.they-

-are.not: health physicists.~ .

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Recommendations '

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The GA-T efforts already initiated with the offsite responding organi~zations should be expanded to include an exercise involving a~n actual patient-transfer about every.

'two~ years; and more frequent contact for discussion, p~ specific ~ training courses,'and drills'should be held as L_

often as:possible.

h GA-T. should consider notifying Scripps Memorial Hospital as soon as any injury requiring hospital care is-7 identified; . This provides the-hospital the maximum amount

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of time to prepare'its facilities. The hospital may

_ prepare for a patient that eventually does not need to be h transported, but-this would seem preferable to having.only Na three to four minutes notice. .(If a patient is loaded in

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? . . an ambulance, the travel ' time from GA-T to the hospital is

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I less than five minutes.)

-GA-T should consider contact with the County Emergency

( ;'

. Response Programs in'an effort to establish a. clear

? -delineation of offsite agency responsibility.

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' The GA-f Plan should use the State of' California PAG which

, is 0.5 to' 5- rem rather' than the EPA whole body PAG of 1-5 rem. (As a note: 'the-thyroid PAG. referenced is still

correct. _In addition,~ EPA no longer states a life saving

. limit; however, the State may still include it.)

, I. Radiological Safety The inspector's' review of the Health Physics, Radiological Safety, and. Environmental Monitoring areas' indicated a very comprehensive-program. Discussions with the present Health Physics Supervisor indicated there is an' excellent effort.to maintain and develop new radiological safety programs. The actual assessment of needs in this area is difficult since many GA-T facil_ities are not currently operating. 'The Health Physics staff is currently relatively small. _

The Health Physics Supervisor indicated that management was very ,

responsive, and if GA-T; facilities returned to " full" operation, identified Health ~ Physics needs would be met.

(1) Organization and Staffing

~

The licensee at this time has three Health Physics Technicians, one Environmental Monitoring Technician and one Radiochemist.

The three Health Physics Technicians are recent hires, i.e.,

they were hired at various times since March, 1986 to replace

..the three Health Physics Technicans who retired at that time.

The licensee was able to retain the services of these retired' experienced technicians for several months past their' retirement dates to supervise and provide on-the-job training to each of the new technicians so that there would be

. continuity and adequacy of health physics coverage during the changeover of personnel. Some of these retired experienced Health Physics Technicians are also currently available on a recall basis should the need arise. According to the

, Supervisor of Health Physics, the new Health Physics Technicians are progressing well in gaining the needed experience and have reached about 70% of their full potential.

i Budgeting for Health Physics has been cut as result of the licensee's method of accounting. However, this decrease'does.

not affect staffing or adequacy of Health Physics coverage. In light of the present workload, the cut in budget for Health Physics appears to be justified and the current number of Health Physics staff is adequate. It-is noted, however, that certain practices.in the Health Physics Program are in need of improvement, ,

(2) Observations:

a. Leak Tests The' leak. tests conducted by the licensee are not in accordance with license requirements. License Condition 21 specifically requires that leak tests are to be ,

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Iconducted for' periods 'not to exceed,'six months. . However,-

,thenlicensee<usestits own.definitioniof'the leak' test-

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m p'eriod'which'allowsia grace period'of,a. month in excess of ,

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the six-month requirement.wiNevertheless no violation of- a" ~

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this> license condition was cited since the Supervisor of-

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. Health Physics; stated thatsthe; sources in question had.not 3; w '

~been used during this grace" period. - According to licensee' .

<a '" representative ~s, the leakL test procedure will be changed,

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3to be~in compliance with the' license' requirements. This '

, will be, checked during.the next' inspection'(87-01-04).

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b; -Air Sampling at'HotJCells' It was noted that tygon tubing is used on the inlet side.

of two; fixed air samplers adjacent.to the low level hot n:

cells. iThe use of tygon will resultjin inaccurate

sampling.results' because'_ of the' electrostatic! attraction *:

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for particulates by the'tygon. Similarly, a ribbed' rubber

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hose is used on the inlet side of.the. air sampler adjacent-~

to~the high level hot cell. .The.tygon and rubber sampling

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> linestshould be replaced with sampling -lines of suitable -

, material. This will be checked during the next inspection: -

'(87-01-05).

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c. Uncontrolled Radioactive Material -

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A vacuum cleaner labeled as containing radioactive .

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. . materials was observed in one of the breezeways on the' second. level of Building 2. The vacuum cleaner was J .c '

' observed to~be unattended and not under. surveillance, an apparent violation of 10'CFR 20.207(b). This section of .

the Code requires-that licensed materials in an _.

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-n unrestricted area.and not in storage shall be' tended under

,' thel constant surve_illance and immediate' control of the

" a licensee. No determination was made of- the' type and ..

' quantity of' radioactive material, if~any, in the vacuum' x-o' -

-cleaner. Thus, whether the NRC or the-State of California, . . .

'had jurisdiction was not established. The vacuum cleaner '

was disposed of as radioactive waste prior to the end of- -

the-assessment.

d. ' Additional Observations A stack sampler at Building 39 was out of service 4

s five days when-the electrical outage for a repair was only oneiday.

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The exhaust air sampling trains at both the TRIGA Fuel Fabrication ~ Facility and the Waste Handling _'

Facility consisted of PVC piping and included at

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least one 90 bend in each system. This will be

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checked during the next inspection (87-01-06).

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in a restricted area for about'two months'after-

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cleanup of a spill. .The exposure to workers.from

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this material;even if not significant is viewed as a

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.  ; .. poor health physics-practice. .

.*j ,.j o . . *Theforegoingare;examplesofpoorhe'althphysics[practic's' e

'that may be. indicative of:the limited experience of,the current-

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Health Physics' Technicians.- .

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Recommendation-

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r s~ GA-T should assure that' the Health-Physics Technicians _ . .

L - training will. include. participation in the' audits ~that- -

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assess the' adequacy of the condition of: site' radiological -

' ; safety support systems. . S

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c 5.- Lessons ~LearnedIte'es.(NUREG-1198)i q a

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A' .' . Item 3.1.1.2(1)M , 4 The individuals" responsible'fdr development, maintenance, updates and implementation of the contingency plan should be clearly .

identified at both.the corporate and siteilevels.

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<Esaluation ',. .

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-The individual'at'GA-TJwho ha's the ov' era 11' responsibility for these actions relating to the contingency plan is1the primary EC.

i According to the.. primary ECL the individuals assigned _the E

responsibilit for the'various elements of the contingency plan are -

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- the managers;who ha~ve the responsibility in1the corporate structure h for these area's, e.g., facilities,; medical, safety, etc. It appears s

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~ that GA-T is meeting the requirements of this; item.

~

P B. ' Item 3.1.1.2(2)

,nf Audits of-contingency plan implementation should be' conducted by. -

l

, individual.s not having direct implementation responsibility and the

. audits should include evaluation of the appropriateness of the plan, a procedures, facilities, equipment (including location of facilities

'and equipment),- training and periodic exercises in the spectrum of l '

accidents or emergencies possible at the facility.

1.

2 Evaluation O *

<[ GA-T has no formal audit plan in'plac_e forl evaluation of the p ' appropriateness of the plan, etc. as recommended by thi- item.

p' # According to the EC who has the overall responsibility for i.he contingency plan, GA-T' believes that its method of sending'the

_ Radiation Contingency Plan around to the various managers and i.

responsible individuals for concurrence as stated in the Radiation

, , Contingency Plan in essence fulfills the same requirements as that

.'of an audit. However, it is noted that these individuals are the 4

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same individuals who-have various responsibilities-for the-implementation..of the plan.

-A formal audit plan of the program carried out by cognizant individual (s) who have no directiresponsibilities for the program has many advantagesJover the concurrence method used by GA-T. A major. advantage'is to provide a fresh and different perspective in the overview ~of;the program. .GA-T should. revise its_ Radiation

~

Contingency Plan and establish a; formal audit program which is conducted by individuals who'have no direct implementation responsibility for the contingency; plan. (87-01-07) '

C. . Item 3.1.2.'2(1): ,

. A' systematic training 'progkam should. be established to familiarize all plant personnel with the. general' contents of the contingency plan and appropriate response actions. Specific training should be provided to individuals (both site and corporate) who might be assigned specific resp ~onse functions and responsibilities.

Evaluation- ,

It appbars that GA-T is complying with the recommendations of this

. item. The training is administer.ed under.the auspices of two individuals,.i.e., the Supervisor of Emergency Services and the Supervisor of. Health-Physics. The Supervisor of Emergency Services is responsible for the implementation of training and documentation

'ot the various courses related to emergency preparedness while the e Supervisor of Health Physics'is. responsible for the implementation .

of the training and documentation of the Radiation Safety Course. A review of-the training-of randomly selected emergency response individuals indicated that the training was current for these individuals. It was also noted that training sessions on the emergency plan were. held on December 11 and 12, 1986 for the

~ Emergency Response and Recovery Directors.

Records of training are maintained on two separate computer systems.

In the computer records maintained by Emergency Services, there is an entry space for the Radiation Safety Course conducted by Health Physics which is left blank because Emergency Services is not responsible for this course. -It would be a distinct advantage if the dates of training for the Radiation Safety Course were provided to Emergency Services so that the emergency training records would

-be current and complete. It is conceivable that under the present system that a person could be listed as being currently trained for the appropriate emergency response courses but that person's x training for radiation safety had already expired.

Each of the two computer record systems is essentially a master file of all individuals who have ever taken the courses. Under the present system there is no way to determine who on the list are active or inactive without comparing the computer records person by person against.a document of a list of persons considered to be active or inactive. 'It appears that the computer programs could be 1

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                                                                        ' Veasily' modified to' provide this informationb Forfexample, thel ' "

( t , ' active indiv'iduals'could be designated by an' asterisk?' This would lL J.. '

                                                    ->                       ,          simplify :the' extraction of information from' the"computerfsystems                                                                                                     - '
        F                                       -

ithereby saving time as~well'as: enabling mana'gement;to have.a'better '

                                                      -                             2 oversight of emergency)trairiing."                                                                   -         4 M.                                                                       -

1 e' '

                                        ,                                            .The'licens~ee'islin! essence complying with~the recomme'ndations~of'                                                                                                      N,'.   '

a, ,c this; item.3The. Emergency; Training. Record System could be further . '

                                                                                       ' improved by! incorporating:the4 dates of Radiatio'n Safety Training:

Ar4 -

                                                                                       .into the computer.. records of-emergencyltraining maintained by the
                                                                 ~
                                                                                      ' Supervisor of, Emergency' Services therebyJestablishing a: complete

^

              ~
                                                                                 ,. record. system for the' training-'of' Emergency! Response Personnel.-
                                  ,                                                     Further improvement"could. ce achieved by modifying-the computer -
                      ^
                                                                                     . programs of the-training records maintained by. Emergency Services 1
                            ~

and Health' Physics' to enable'the identificationLand extraction'of'- - 3, 'information forfactive/ inactive: persons in the program; 1 D. TItem 3.1.'2.2.(2). , c 7'T

                                                                                                                                                                                               ~
                                                                                    -Offsite organizations n o might=be' requested-to support an emergency' response.should be invited to attend training specific to the                                                                                                         s e                                         1e            ^
                                                                                      . response expected.

i, ' -

                    '                                      ~
                                                                    ~

Evaluation' . E , . Y f" LAfcopy of a letter inviting'offsite organizations to participate in , k 4 -

                                                                                     ' an exercise conducted'in 1983' was reviewed.. :This was' verified in                                                                                                      '

3 discussions" held with(representatives of tlie fSan Diego Fire

                                                                                                       ~                                       ~

i DepartmentTand the' San Diego Police Department. . ~, w . .

                                                                                                                                                                                                                     ~
                                                                                     .According to_ documentation provided by the-EC, there had been two-offsite exercises: held'which involved' offs,ite organizations and.
                                                                                                                      ~

involved simulated contaminated personnel. One had been-held in i "1979 and the 'second(iir1983. _ Documentation regarding these exercises involving ~offsite organizations is available only for the 1979 exerciseF A memorandum dated: September;.27,1983, is on file regarding a meeting with offsite emergency response organizations.

                .                                                                   ~Offsite drills are currently b.eing held every four years. -Thi s -

,- y frequency doesnft seem to be adequate,to' maintain a state of

                                                                                   ' readiness..particularly with the hospital!s handling of contaminated
                                                                                     -patients. This was evident from the discussion held with hospital
                                                                                                                          ~

personnel'(See Item 43.3;3.2.-)..The offsite drills should be held on ' ca more frequent basis and the documentation of these drills should i' , be'. improved (See Item 3.1.3.2.(1)). (87-01-08) m . -

                                                -a                 E.                   Item 3.1.3.2.(1)
                                                                                    ; Drills'and exercise's involving substantial staff response to a

[  : spectrum"of simulated emergency situations should be conducted periodically. The simulated events should be based on prepared ~ scenarios to demonstrate specific objectives, and they should be l- observed and critiqued by qualified personnel. Any deficiencies i 1

                                                                                  +                             .-

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o b' serv'ed should be ' evaluated and responsibility for corrective-i _

                           +

action assigned and followed. .

                                                                                                                                                             ~ '
                                                                       .Evaluat' ion
                                                                                                                                                          ~

'a- , :r - Onsite drills.are held periodically. Fire dhills are held annually,.'  :

< : nuclear criticality drills.every six; months, and Health Physics, drills.are held quarterly. . Documentation ~of the drills and:

                                                     +

critiques are maintained by the cognizant groups responsible for-

                                                                       !ca.rrying outithe_ drills. Since the EC'is responsible for overseeing

-the company's. emergency planning, he

should maintain.a master file

                                                                        'of the documentation 'of:the scenarios, critiques, etc. of drills 'and
                                                                       ; exercises held. Additionally, the cognizant groups responsible'for
                               ~
                      .m.        x                                     . conducting the drills'should provide the EC with duplicate copies of
                                                                       -the documentation relating to the drills such as' scenarios and ,

critiques. e

                                                       ' F.             ' Item 3d.3.2.(2)

Drills and exercises should periodically include the:offsite '

i 1- organizations which might.be called upon for support (local-police, -

                                                                         ' civil. defense, health departments, etc.), as well as corporate
                                                                       ' personnel.
                                                                       ~ Evaluation i                                                     .;
                                                                  ' ' Discussions held with' representatives of the; San Diego Police Department, the San Diego Fire Department and licensee representatives indicated that the. licensee maintains a'close                                                                                      .

working' relationship with these two' groups through, periodic tours; 4 and-trainingiactivities. These organizations participated in_the two offsite drills held in 1979 and 1983 but did not participate in the onsite: drills held by the -licensee. Because of roles and

responsibilities of these-two support organizations an'd because of ,

                                                                       ;the close relationship with the licensee cited above, the frequency P                                                                       ~ of participation-in drills'and exercises is not considered to be as
                                                                       . crucial as-with other support groups because of-the: state of _                                                                             .

readiness;of those;two organizations. 'There-is~also evidence of an

                                 ~

ongoing familiarization program with new members'of the Police and'

                                                                  - Fire Departments.

The. licensee.should continue their attempts'to obtain the I cooperation of the San-Diego County Emergen'cy Services to

                                                                                           ^

participate in the offsite exercises. ' - ,f , [G. , Item 3.1.4.2.(1) a

                                                                                                                                       ' '      t a

IConsider requiring a'de'signated' Emergency 0psrations Center (E0C) onsite and an alternate E0C either offsite or in another onsite UE location which is unlikely to be impacted by the incident. The E0C D' ^ and alternate-E0C should contain adequate communications capability

and accommodations to provide for coordination of the onsite emergency response activities and notification and coordination with

}.

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               ^

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                                                     - 32      '
 /v..+                                           .

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                                                                      +
                    -offsite s'upporting organizations. The E0C or alternate E0C should be accessible 24 hours a' day.

Evaluation , The licensee's designated E0C,is-Security' Station No. 1 located in the Administration Building'(Building 1). .The adjacent. office spaces are also available if needed. The licensee has not designated.an' alternative E0C because according to its assessment,

                    'the designated ~E0C should remain; tenable under"any emergency situation.

Security Station l'is one of the several base stations for the licensee's radiocommunication system which is comprised of a network of radios operating on two frequencies. Both frequencies are monitored by the licensee. .The:EOC also has a dedicated hot line to the NRC. Neither the San Diego County EOC nor the. City of San Diego's E0C'is specifically mentioned in the licensee's plan. The i latter facility.is some 13. miles from the site, is accessible 24 hours a day and adequately equipped with communications equipment and other required accommodations. The licensee appears to have a satisfactory E0C facility and communication system. H. Item 3.1'.4.2.(2) locations of emergency equipment and kits should be reviewed by the_

                    'NRC and licensees so that in the event of an emergency in a given facility location, or inaccessibility of a large portion of the facility, access to adequate emergency equipment'and facilities, including emergency decontamination facilities, can be assured.

Equipment caches should be in multiple locations. Evaluation The licensee has a Health Physics van which contains a variety of emergency response aquipment including self-contained breathing

apparatus (SCBA) and various Health Physics instrumentation. This i van is kept on a standby basis and is available for use by Emergency Services during the offshift hours when Health Physics personnel are not available. According to the Supervisor of Emergency Services and the Supervisor of Health Physics, there are emergency supplies situated at various locations onsite. Necessary emergency equipment and kits are kept at the Medical Department. They appear prepared L

to give initial medical response to chemical exposures. The licensee's approach to assuring availability of emergency equipment appears to be an adequate one. I. Item 3.1.4.2(3) f Consideration should be given to providing strategically placed " air capsule escape units" to allow workers to escape from portions of a-facility in which there exists a potential for exposure to toxic fumes for more than a few moments. k I

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valuation ~ ' *

                     ~

Emergency escape and entry.deGice'SCBA: units were i located in , ,

       ,                                 .      _..                 ;potentially; hazardous areas.. Employees appear trained.1~However,                                               . *
                -                            *                        .the inspectors =notedJface. masks:were not sanitized after use ands
         ,                ~,             .o                          ;were; stored on top of' cylinders unwrapped in Bui_lding.37. ?Also,
                                                             ,,       _ emergency air packs were _not;placed at the mostJappropriate"
                                           #                        l positions.' ;A complete re-evaluation should be made.of escape
                                                                    ;    devices, specifically focusing on their strategic locations in '

cQ- '_  : Building-39. .,

                                                                                  .                                                                                                                 c J.                  Item -3.1.4. 2.-(4) .                 ,

3

                                                                                                              ,          3 ,

The facility communciations: system should: include a radio. system ' - compatible with local police or other offsite responder .

                                                                                                                                                                                   , ,i communications systems. In addition, the licensee should attempt toj identify beforehand t6 local and. State Police, insofar as
                                                                      'offsitel individuals who would befcalled on'for supportlinthe                               practical, event                                      '

J of an emergency atLthe site. Radio communications with police officials;during an emergency can. resolve specific is' sues. '

x. ,

t

                    ,.                                                    Evaluation                                 '
                                                                                                                                 ^

aj . - Thellidensee's radio

• i:dmmunicatioh system is. compatible with that of; ,

the San:Diego Police Department-and the_ San Diego Fire Department. ~ Licensee representatives stated that although this is the_ case,',they , . 1 would still prefer to use 911 to call either of.these two agenciesi

                                                                      'because of the. media's-practice' of monitoring these radio frequencies'. .The' licensee has. specific names ~and elements of-offsite ' organizations to call incorporated into their. emergency-                                                              >

plans,; including the . San Diego' Police: Department. - The licensee's radio communication' system and;its' procedure for the identification-of' emergency personnel both appear-satisfactory.-

       +                                                K.                 Item 3.2.-2.2.2(1)

When there is significant media interestLlocally during or following an event, regularly scheduled press; briefings coordinated with licensee,~NRC and State responders sho'uld be considered. The current experience indicated the value of the " unified voice" approach for updating the status of..an event. ..The result was the much reduced impact from separate inquiries to response team

                                                                       . members.

Evaluation A review of the. licensee and City of San Diego emergency plans does not indicate.any specific provisions to incorporate NRC or State coordination in media relations.

L. Item 3!2.2.2.2.(5)

   . ~
                                                                       'The ne'ed for establishing standardized sampling and sample preparation procedures and the means of intercomparing laboratory ey y

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resultsishould'be~ recognized

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multiple. ,, organ,iza,tions.- y,. : ? > ',g% !and e - met; early inany event: in ( [ "~g : % ?d y . ,( n

                                                                                                                                                              ~'

lev 51u' tion M

                                                     ~

U - a - m .f :a K- %K , - The licensee's* Health Physics 1 Laboratory routinely analyzes? T.: - N i environmentalisamples as part'of;its' environmental monitoring-Eprogram, but doesn't participate'in any.. laboratory intercomparison ' z , program,such'as'.that established by;thel EPA.- The licensee should

                                                                                     -participate;in'the-EPA's laboratory-intercomparison program for^

environmental < samples. . Participation by the. licensee in such a program would have many. advantages forsthe licensee as well.

2Discussionsiheld'with the' Supervisor'of Health Physics indicate that

                                                                                      .the licensee is interested'in participating in such a program.-

M. Uitem 3.3.1.2.

 ,                                                                        ~                                                     ,
                                                                  +

e . m 'Iri:the' event of an emergency' involving an impact on public health ' E 'and: safety,1 other federal agencies may..need.to respond on a timely

         ,                     .                                                      tbasis with personnel, equipment, or procedures for obtaining
                                                                                      ' pertinent.information. cThese agencies-should be notified of an event as.early as possible.

Evaluation ,

                                                                                                                                                                                                    ~
         <                                                                         > According to the EC, the criteria which would be used as a basis for
                                                                     '~
                                                                       ,                  the.' notification of offsite support groups is the' probability of 2-offsiteirelease. This is in accordance with the statements made in-
                                                                            ^ ~the Radiological-Contingency Plan. It is of interest to note that
                                                                         ~ , ~ .according to the21icensee's Radiological Contingency Plan,.the-e                                                                                   offsite. doses for the maximum credible accident is well within the

_; PAG of EPA. The-licensee's criteria for the notification of offsite

                                                                                        ~ support. groups appears to be satisfactory.'
                                                                  ' N .-                   Item.3.3.2.1.2.(6 e
           $%                                                                              Personnel of local agencies that might be' called upon to respond to emergencies should be given training (see Section 3.1.2, Training).

t Evaluation , y .The licensee conducts periodic training sessions with the San Diego= Fire Department and the San Diego Police Department and appears to

                                                                                      .have a close working relationship with'these two groups. .(Training
 <<-                             4 <

iof hospital personnel will be discussed under 3.3 3.2.) There

                                       ~
                                                                                      ,doesn't' appear to be much interaction by-the licensee with other
                                                                                       -support groups such:as the San:Diego County' Emergency Office and
        '*                                                                                 Scripps Memorial Hospital. iThe licensee should make continuing efforts to interface a'nd train with all outside support groups.
                                                                 - 0. _ Item 3."3;3.2.                                                 '

y [ Hospital? staff who might reasonably be expected to deal with

                                                                                       ~ injuries'from'a major accident should be, trained to deal with all 3                                                                                                       , ,

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g.- - 7, ( '- ' .' aspect $oftheinjuriesMRadiologicalplansfandtheir:useindrills s -ul fare 1 desirable. ,D ., '.~ < yx, , 7

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                                                                             . Evaluation.
                                                                                                                     +
                                                                                                                                    ,             m.

W - _ F ..

e. ,f :The hospital'~s facilitiesifor_handlihg'co'ntaminated patients was '

itoured and'a discussion wasrheld with.the hospital's Nursing-J

                                                              .          1Coordinato Fand:the. Radiation Safety Officer;who are' responsible for                                                                                             i
                     ,,                                                    Sthelhospital's' program.in this area.4 According to the-hos'pital
                             's representatives,.the'last' exercise 3 involving contaminated patients'                                                                                                  '

was held.in 1983. The only; interface theyLhave:had with~the_. -

                                                                              -licens'e~    e

• since' then' was a -few years ago when the Manager of -

                                                                             ~~L icensing, Safety and Nuclear Compliance,' provided.the hospital with-Evideotapes on.the' handling of contaminated patients._;It appears.
                                                                            ..that' the' hospital representatives _ have-a rudimentary knowledge of 7                                                 theThandling of contaminated' patients land were' eager toilearn more.                                                                                    _
               .               f                                            fBased on=the' discussion held,'the assessment.tcam representatives; willfprovide the hospital. staff with some basic references and other                                                                                                   :

P 'res'urce;information on the handling _of contaminated ~ patients. -A~~ o numberiof suggestions were also given to~the hospital, staff ~during

                                 ,                                             the' visit'     . - ,
                                                                                            ,~<.v
                            ~_

The' hospital's emergency kit for use in.the 'hsndling"of contaminated l patients Was.also inspected by the assessment team representatives. The emergency kit appeared to be.well maintained. However, it took

            ~

, the' hospital representative ^s~about 15 minutes to locate the ~

                                                                            ? emergency ' kit although it was supposed to-be in a locked storage cage. l n                                                                                 .s                                                                          :        ,

s , 4It was noted;that the hospital representatives were very cooperative

and' motivated to be ready to provide the licensee withithe required. .

                                                                            ' services should there be a need. The licensee should' reciprocate by interfacing with the-hospital on a much more frequent basis to
                                                                         ,     provideithe' hospital with the information,. training, and whatever-assistance the hospital needs to maintain its readiness to provide-the required ~ services to the licensee. . Included in the' assistance!
                                                                            ?that should be provided are periodic audits:of the hospital's

{ capability and readiness to handle contaminated p'atients. P. Item 3.3.4.2.- g 3.. Radiological contingency planning should include site control plans E - 45 and methods for implementing site access control. Local law n enforcement groups that might be called on.in an emergency should be W x trained. %l Evaluation-

           ,                 ,                                               . Law enforcement is-the role and responsibility of the Police Department. :The. licensee maintains a close liaison with the San Diego' Police Department through periodic tours and training g

activities. V , 4 5 o ,e t

                             <                                                                j                             ,

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                                                                                                                                                                                                          ~

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36 1 F I r , . 4~ To: preclude the possibility of;the licensee's: emergency personneli

c. .being denied access to the site when responding to an emergency, the-

_ ~ licensee ~has' imprinted in red: letters on each of:the emergency x ' Dresponse personnel's badge." emergency response, personnel. : . .. .;".

,                                      w           <           -

According to,the Supervisor of' Emergency; Services, this system has-

                                     .                    g                    : worked.well a~                s evidenced-recently on an a~ctual emergency with no
                                                   ^N                               emergency response personnel.having been-denied access to-the site-4                                        '

by local law enforcement: officers. The training provided to the San Diego Police Department appears to be: satisfactory.

                                                                                                                            '                                        ~
                                                           ~

Q., Item 1 2.2 .

                                                                                ~N RC licensees should belresinded through anlIE Information Notice of                                                                     I

their.- obligation to-report releases .above reportable-quantity limits

                                                                                ,to their National Response Center and the potential of a criminal penalty.under Comprehensive Environmental Response, Compensation and J                                                                  . Liability Act (CERCLA) for_ failure'.to do so.

,. ~ Evaluation '_

                                                                                ~

Federallregulations conderning the; reporting of certain 'relea'ses, 4

                                                                                ' spills, and: relevant incidents to.the National Response Center and other related matters were7 discussed with the licensee.
                                                                                                             ~

R.-~ It'em 6."2 '

                          ^
                                            ~ '

rn L - i

                                                                                . Recognizing th'e need tolissue the report of the assessment of_the _

short, term health effects promptly,'a schedule should be established,

                                                                                                                    ~

within that report to; ensure the assessment and follow-up of the

                                                                                 -longer range effects. 'The'latter sh'ould be included in a l supplemental ' report.-                                                     -

Evaluation o : 'It would'appe'ar appropr ate that local level entities be' involved in c , ;the' development of such health effect reports. For example, the

                                                                                ' County of San Diego has-a health physicist on its staff and it also                                                                      i

has.the: responsibility to provide short and long range support in l radiological emergencies -- including those that might occur at the GA-T plant. This aspect deals specifically with Radiological

                                                             ^
  ,                                                                                Monitoring but should also include chemical exposure and chemical G                                        =-                                          incidents.

6. (~ Exit Meeting

                                                                                                ~

The results of the assessment were discussed with the licensee's staff identified in Section~ 1. The topics highlighted for the licensee's 3 , attention included: .

           ?^                                                   A.                 Open Items
        ~

87-01-01 Review qualifications of nuclear safety analysts and

     '%                                                                                              independent reviewers.

7 ( a

.. * -'.                              b.                -.        -s      . . _ . ,         .A-   .   .--m--    -, ~-+- --. _,. --. - ..-~~__- -- .-- _ - . _ ,,_ .- ---.~,- -._,, _ ..- ,.                   ----.. ....e

     .           F                         ~\                                                                M 7, oye 37 87-01-02,. Review stat'us of Building.37 Dump Sink Analysis documentation file.

87-01 Review the licensee's check:for incompatible storage'of chemicals. .i.

                                                                                    ~

87-01-04 Check licensee's leak test.p'rocedure for compatibility

with'.the license _ requirement.

87-01-0'5' Review corrective action on1the hot cell air sampler. using tsgonitubing; l

                              ~87-01-06. Review corrective action on PVC tubing with 9'O bends in-the' exhaust air sampling systems at the TRIGA Fuel JFabrication~and"the Waste Handling Facility.

87-01-07' -Review the licensee's' plans for an independent' review of'

                                                  - the Emergency and Radiological Contingency Plans.

87-01'-08 '_RAview the licensee's pl'ans for increased interfacing and more frequent exercises with Scripps Memorial Hospital. B. -Other Topics Participation'in Hazard. Communication Training Program.

                               *~

Support CRSC in its essential functions. Enhance CRSC members status.

                                                ~
                                          -Assure nuclear safety criteria and license requirements are
                            ~

met. Review of work station criticality limit signs.

                                                                                             ~

Exclusion of unsafe geometry containers. l -. Identifying exceptions to normal controls in SNM vault storage. Need for improved communication between successive Managers of Nuclear Safety. Maintain current Nuclear Safety Standards and Guides. ! Additional lockers may be needed for flammable liquid storage. Pre-Fire Plan upgrade. l Broaden Hazardous Materials Locator Information. L Review size of Emergency Services staff. Review propylene storage. l

                                                                                           .n - .                            , . ,_ .                                                    ,             .
                                                                                                                                                                                   'k                                                                                          ^
                               ~

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                                                                                                        >ProperlyT1abel containers of flammable: liquids.                                                                                                     .                  <
                                                                                                                             ..,.er, p'y,-
                                                                                           'o .

rImproveihaz'ardous' material transfer pipes.-

e. . ,. ,

4= .- .

                                                                                    ,     ;o " !Put safety-related valves and gaugesLonTa: Preventativee

. +, , _ .

                                                                                               ,.           Maintenance: program.
    'n - u 7                                                     ;/ Jo? " Assure 9toragetanksareproperlygrounded.                                                                                                                                                                                               !
                                                                                                                             ..~

."e '

                                                                                      ,..                .                                          1.                                                    m.

o: t Consider / reducing the inventory of-hazardous materials.

                                                                                                                                                                                                                                                                     ~                                          ~

m m . y. Conside.r;independentexpertevalubtionof-sitefiresafet.

                             '                                                                                                                                                                                                   ^

Cons'lidate1 o scattered.designinformation. l -

                                                                                                                                                                                                                                                                                                                  ~
    ,        ~                                                           <
                                                                                             , y
 ~'
                                                                                            *-          lMaintainup-to-date'"asTbuilt"drawingsonproc$sssystems.

[ ,: Continue:currentcriticalityalarmtest(frequency. . M  ;*- , .

                                                                                                      ; Test TRIGA fines furnace control; system before operating.                                                                                                                                                '
,              . .                     x                                                              -Te'st equipment' safety systems to assurs readiness.

1 ~

                        *                                                                 ~*

LImplement'PMonprocessJequipment. Expand Quality " Assurance to process equipment. n - c'-

                                                                                                      ^
                                            -                                                              Continue' support'of Plant Safety. Committee.                                                                                                         '
      ',                                                                              S*              ; Enhance line-manageme~nt involvement and responsibility for v                           +                                                                        . safety in their_ areas.

l

            ',                                                                                        ' Grade' safety performance by area.

N *

                                                                                                        ; Include. safety ~ performance assessment in evaluation of managers                                                                                                                '

(by area). s

                                                                                                        ' Review adequacy,of' safety audits of smaller labs.

[- . Immobilize gas bottles an'd their carts. y .. .

Eliminake" incompatible'chemicaistorage.

                                                                                                                                        ,3                                                                       .
                                                                                                                                                                                                                                                                                                                  ^

Consider toxic gas monitor installation. x c , , S Combine.trainingi$1 formation"intheSuper'visorofEmergency

                          .                                                                                Services computer

_ c file. L . , , ,

                                                                                                                                                            -           +                                                          -
                                                                                       <*-              .IncreaseLinterfacing with;Scripps Memorial Hospital; transfer a patient in.an exercise;at least biennially.                                                                                               (Give maximum
         ~

notice before. transport.)-

                                                                                                                          ,                                                                                         a.                ,

1 Est'ablish contact with San Diego County Emergency Response Office. c  : t

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Consider' State'of California! AG's P vs. EPAs.

                  +                    -

Therecebt_by-d'evelopedhazardousmaterialsemergencydocument

            ~-
                                            ~ does not . appear to meet- State and Federal requirement.

Consolidate the five Emergency Plans into sections of a single ,

         ,-                                -document.

Possibly develop _a functional response matrix. Amplifyhazardousmyterialssection. Onsite hazardous material storage appears adequate. Licensee has good rapport- with most offsite agencies.

                                    *-         Recdrds_regardinginterfacingwithoffsite'agenciesshouldbe improved.

Appropriate' letters are'on file from offsite support agencies. Contacts and-telephone nu.abers of response agencies should be listed in the plan. The-licensee acknowledged that the team assessment was beneficial and that his staff had responded as practicable-to short-term items. The Chief, Nuclear Materials Safety and Safeguards Branch (NRC-RV) reemphasized the.importance the NRC attributes to safety-and underscored that close attention'will be given not only to the Health Physics ! staffing level but to the scope and depth of the Safety Committee and the-CRSC as well, t; I' ( t 4 l-

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