ML20283A834

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General Atomics Inspection Report 07000734/1994003
ML20283A834
Person / Time
Site: 07000734
Issue date: 10/05/1994
From: Collins S
Division of Nuclear Materials Safety IV
To: Edwards J
General Atomics
References
IR 1994003
Download: ML20283A834 (14)
v • d • e


Text

NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON , TEXAS 76011-8064 OCT 5 l994 Docket: 70-734 license: SNM-696 General Atomics ATTN: J. Edwards, Vice President General Council and Secretary P.O. Box 85608 San Diego, California 92186-9784

SUBJECT:

NRC INSPECTION REPORT 70-734/94-03 This refers .t9 the routine, unannounced_ inspection conducted by Mr . C. A. .Hooker -0f this offic~ on Sept~mber 6-9, 1994. The inspection included a review of acti vities authorized for your General Atomics facility.

At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed report. Additional information relative to this inspection was also discussed with Dr. K. E. Asmussen of your staff on September 14, 1994, and additional employee exposure evaluations were provided on Sept~mber 22, 1994.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress. The results of this inspection are documented on page 1, in the enclosed report.

Within the scope of this inspection, no violations or deviations from NRC requirements were identified. However, the inspection identified a concern with the currentness of your Radiological Contingency Plan as it relates to criticality accident assumptions used for estimating potential offsite radiological consequences. This matter is discussed in Section 1.6 of the enclosed report. Based on the telephone discussion on September 14, 1994, between Mr. F. A. Wenslawski of my staff and Or. K. E. Asmussen, Director

  • Licensing, Safety and Nuclear Compliance~ it is our understanding that you will _submit to the RIV office by Octob~r 14, 1994, a plan and schedule that delineates your proposed actions to resolve this matter.

Also, Section 4 of the enclosed report describes circumstances wherein the actions on the part of your health physics staff to evaluate radiation doses to employees in controlled areas were less than diligent. We call this to your attention *for corrective action as you deem appropriate.

In accordance with 10 CFR 2.790 of the NRC's 11 Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

ML20283A834

General Atomics OCT * ~ 5 1994 Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, o 1ns, irector Division of Radiation Safety and* Safeguards Enclosure :

Appendix - NRC Inspection Report 70- 734/94-03 cc w/enclosure:

ATTN: Dr. K. E. Asmussen, Director, Licensing, Safety and Nuclear Compliance P.O. Box 85608 San Diego, California 92186-9784 State of California

> C.

APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV Inspection Report: 70-734/94-03 License: SNM-696 Licensee: ~eneral Atomics (GA)

P.O. Box 85608 San Diego, California Facility Name: General Atomics Inspection At: Torrey Pines Mesa and Sorrento Valley Sites Inspection Conducted: .. September 6- 9 and 14, 1994 Inspector: C. A. Hooker, Senior Fuel Facility Inspector Approved: £J ~

Frank A. Wensawsi,Cief Materials Branch Inspection Summary Areas Ins pected: Routine, unannounced inspection of emergency preparedness ,

maintenance and surveillance testing, radiation protection, criticality safety, operations review, and followup on open items.

Although proprietary information was reviewed during this inspection, such information is not described in this report.

Results:

  • In the areas inspected, the licensee's overall performance appeared adequate to meet their safety objectives. However, the inspection identified an issue relative to the inadequacy of the licensee's Radiological Contingency Plan (RCP) to demonstrate the potential offsite radiological consequences due to an accidental criticality event based on current site operations (Section 1.6). Additionally, maps in the RCP are outdated and do not adequately reflect the industrial growth near the licensee's facilities (Section 1.6). The licensee's inattention to detail in this area was viewed as a program weakness .
  • The inspection also identified that the licensee had not diligently evaluated the potential radiation dose of individuals working in a controlled area (Section 4).

Summary of Inspection Findings:

  • Within the scope of this inspection, no violations or deviations were identified.
  • Inspection Followup Item (IFI) 70-734/ 9402-01 was closed. This item.

involved the licensee's evaluation of the potential dose to members of the public and personnel working in controlled areas. No violatjons were identified (Section 4).

Attachment:

  • Persons Contacted and Exit Meeting l.

DETAILS 1 EMERGENCY PREPAREDNESS (88050)

The licensee's program was examined .to determine whether the commitments delineated in the RCP were being effectively implemented, and whether the program was capable of_protecting the general public and facility staff.

Federal Register (FR) Notice 54 FR 14051, dated April 7, 1989, announced the publication of the final rule on emergency preparedness for fuel cycle and material licensees. Previously, emergency plans were submitted under orders issued in 1981. The FR* Notice stated that at the time of license renewal, licensee's must resubmit their plan revised to conform with the new rule as part of their renewal application. The r_1,11e; 10 CFR 70.22(i){l) effective April 7, 1990, delineates criteria for* :~nd *the , contents of emergency plans.

Section 8.5, "Radiological Contingency,,Plan,11 Part II of the license requires the licensee to maintain its RCP submitted to the Commission on May 25, --1984, and as supplemented and revised through September 10, 1992. By letter dated November 22, 1989, the licensee submitted an application for renewal of GA's special nuclear materials (SNM) license, SNM 696. This submittal was prior to the new rule, 10 CFR 70.22(i)(l), becoming effective and the submittal did not provide a revised RCP . . As of the date of this inspection, the license renewal application has not been approved. As previously approved, the licensee's RCP dated August *-1992 and as rev*ised -through SeptemberJO, 1992, is primarily .of format and content of the NUREG..a.0762, 11 St~nda*rd :for-mat and Content for Radiological Contingency Plans for F.uel .Cyc1e and,Materials -Facilities, 11* dated*

July 1981, as -opposed to NRC Regulatory Guide - (RG) *J.67, 11 Standard Format and Content for Emergency Pl ans for Fuel Cyc1e and Materials Fae il it i es," dated January 1992, which superseded NUREG-0762.

By letter dated July 1, 1994, G~ '1ubm{tii~ to NRC a copy of its latest revision of the RCP dated June 1994. The licensee's transmittal letter stated that only minor *.changes were made t_o , the contents of the RCP, however, *the plan has been:,revised in jts::el)tirety::-due , to complete *reformatting* of the document. The *changes pdmarily involved *updates reflecting* changes ih 10 CFR:

Part 20 terminology, nam*es and phone numbers of emergency ~response personnel f -

  • and minor clarification of reporting procedures .. *The .format and content of the June 1994 RCP did not change from that specified in NUREG-0762; 1.1 Offsite* Support Agencies The inspector verified that the licensee .has continued to interface with the appropriate offsite emergency support agencies. The inspector noted that the licensee's interfacing also included site familiarization visits by khe appropriate support agencies i~d invitations .to participate in *facility drills. The latest visit by *. offsite* agencies was in May 1994 by personnel from the San Diego Fir.e Department, :FederahFi re :Department,. and -County Hazardous Materials Agency. The San Diego Fire Department normally visits the site two times per year.

The inspector verified that a current copy of the RCP, emergency response notification procedures, and current telephone numbers of GA emergency response personnel and offsite support agencies were maintained in the licensee's Emergency Support Center (Security Station No . l located in Building 1). The inspector also determined that the security personnel were cognizant of the reporting and notification sequence delineated in the RCP.

The inspector concluded that the licensee was adequately implementing their commitments for maintaining offsite emergency response personnel familiar with licensee activities, and were capable of making the appropriate notifications during an emergency.

1.2 Facility Implementing Procedures The inspector noted _that updated emergency ,fmplement_ing procedures were maintained at each active SNM facility covered by the RCP. These procedures were located at the main entrance to. each :facility along with an updated call 1is t of key emergency response personne1 .

  • Personnel had been trained and were familiar with their respective procedures. No concerns were ideritified.

1.3 faci1ities and Equi pment The inspector verified that th.e emergency response .equipment described iJ.1._ the RCP was being i nyentoried, inspected, and maintained as specified in t he plan and licensee *procedures.

  • The .equipment appeared to be well maintained and cal i brated or,-tested :.at. the. ap.p.r opri ate frequenc_ies. The licensee al so continues to ,maintafo _two w~ll _. equipped -fire truck~_- and 11n emergency command vehicle. During facility tours the i nspector obs~rved that emergency exits and evacuation pathways were clearly marked. No concerns were identified.

1.4 Organization and Training The inspector verified that the emergency response organ\zation was as delineated ii] th~ -.8CP,. . A_r~vie_w of tr.ajn_ing .reGo.rd.s i_nd_icated th.at ea_ch.

member of the emergem:y _r~sponse : organiz,atipn-rcec~iyed ;:Specializ~d annu~l training particular _to .i~e:ir assi.gned duti1~.s,.-: *,Jr_ai.ning_.)nclu~d first aid, the use of fire ; ~xtinguisher$, evacuation procedur.e s, radiologjcal safety, hazardous materials, and the use of self contained breath ing apparatuses. In addition to the training provided to the emergency response team members, the licensee also cqntinu~$ to maintair, -~ fir~ ~_rig_a:de: staff .c onsisting_ o:f *an-emergency servi ~es supervisor and five qual i;f i ed _em_ergency_. serv_ices; technicians (ESTs} .. The ESTs are traine_d3s profe.s,$_io11,a l~ fire fight_ers, certified emerg~f!CY m~dical technicia;ns, .a/'ld, cert ff_j~d.,:t1azardous , chem.ical technicians. The ESTs,; provide *sj_t_e_c,over~g.e:_i4 hours per day an~, seven_days per week. Although the site ESTs ,~r~. fi~~t ~ine responders, they are only-expected to mitigate incipient events . The licensee relies on the San .Diego Fire Department to .~e the responding _party fo_r s:1gnifica_n,t events involving fires, haza~c;ius. ,material~ -= spj-l ls,* and !]at.µral ,d_i sa,s ters... . ';G

1.5 Drills The inspector noted that in October of each year, during fire prevention week, the licensee conducts a. fire evacuation drill at each facility. As appropr;ate, criticality evacuation drills were also conducted semiannually.

The licensee' s last annual -drill to exercise selected aspects of the RCP and invite offsite support agency participation was conducted on December 16, 1993. The inspector reviewed the accident scenario, comments from drill observers, and the followup critique. The scenario concerned a simulated accident where a 55-gallon drum of radioactively contaminated flammable liquid (alcohol) spilled and caught fire while being transpor ted with a fork truck in the lower waste yard of Building 41, Although the San Diego Fire Department was invited to participate, other commitments prevented thei r participation.

The inspector di.scussed the weaknesses identified. by the li censee ' s critique with the Emergency Coordinator (Supervisor, Emergency Services). Based on thi s discussion it appeared that the licensee identified weaknesses were being adequately addressed.

  • The inspector determined that licensee drills were consistent with those descri bed in the RCP and provided adequate training for responding to onsite emergencies.

1.6 Procedures for Offsite Rad i ation Dose Assessment The inspector noted that Section 3.3, "Range of Postulated Accidents," of the August 1992 RCP and the recently submitted .June 1994 revision states, in part, that: (l) the*,range of ..postulated- .accidents .- i.s an~_lyz_ed _in Sectio.n 7. of the Demonstration .Volume of* .t he.*1S.NM-:-6.96;* 1:i cense, (2) ,.the on.e [p~stul at~d accident]

w.i th the greatest ...potential' off.. site .r.adio,l.ogicat.consequence.~= :but lo\'.'_e st probability *is a criticality .in the Fuel Fabrication Fa~ilitY:

[high-temperature gas reactor *(HTGR) fuel fabricatio n facility] at the process liquid dumping site in Building 37 at Sorrento Valley, and. (3) the dumping site is no longer being -used .and this facility has been .4ecommiss.i oned.

Section 3.3 further .states: , . .'~The greatest .radiol.Qgical *cons equences from this accident based on 50% meteorology would be "0.27 Rem whole body, 0.26 Rem thyroid, 0.015 Rem bone.,: and .0,023. Rem :l ung .dose. :.. T~~se doses to individual s working neat ;the1ssite- boundary; for .a hour:s i.ar~well withtn th_e.Pr~J~~tjve Action Guides of:4he Envinin*ment:al Pro~ection :Agency *.. . .*. .

(1 Rem whole body, 5 Rem:thyroid, and~- Rem other _critiql organ )...

Section 7.1, AJntroduction >" Part .1 (Demonstration Volume) of th~ _license app 1i cati on.-states that- an ~ace i de.nta 1 crit i.c~lity 1 is nc;it col)s idere_d .to. be i3: . .

credible acci-derit; although the possible consequences of such an _event are considered in Sect ion 7. 3. Sections 7. 3.1 and ..2

  • provide the basic assumptions,
  • accident scenario, and modeling ,of the po~:tulated er.it ical_ity accident referenced above. As referenced in the Demons t r ation Volume , the licensee's modeling and radiation .dQse estimates .were performed in accorda~ce with the guidance provided in RG :31.*3 4, *"As~µmptjons Used for Evaluatin_g the .

Potential Radiological Consequences of an Accidental ~µclear Cri~icaljty in a Uranium Fuel fabrication Plant/~?.Rey. l ., ~uly 1979 .. i'f~e modelif!g rinvolved *,an ,i -T event with .a .solution system o:f less that d 0O-;galJons,-wlth an iri-i-tial :Puls~. _o f l.OE18 fissions followed successively at 10 minute interval s by a series of

pulses of l.9El7 fissions and a final pulse of 1.0E17 at 110 minutes after the start of the accident for a total of 3.0E18 fissions. The postulated accident involved the transfer of uranium (enriched to 93.2 wt.% U-235} liquid waste into an unfavorable geometry 55-gallon drum located in the liquid dump room.

Section 7.3.2 of the Demonstration Volume states that the dump room was designed to mitigate the results of a criticality accident and was shielded by 24 inch concrete walls, a 16 inch concrete ceiling and had a close fitting door to contain any possible contamination. In modeling the accident, the licensee also took credit for the ext~rior S.75 inch concrete building walls, for a total of 29.75 inches of concrete shielding. To mitigate radioactive effluent releases from a, criticality accident, the HEPA exhaust system for this facility was designed to automatically shutdown when the criticality alarm was activated to mitjgate efflu!;!nt releases.

~-. __ _

The doses described in Se~tion *3~3 of the RCP were based the HTGR facility being 46 meters from the site boundary. Figures 7.3, 7.4, and 7.5 of the Demonstration Volume respectively provide one, three and eight hour estimated doses to members of the public from the above postulated criticality accident .

The doses delineated in Figures 3-8 through 3-10 of the RCP are the same as those provided in Figtires 7.3-through.7.5 of the Demonstration volume.

Items l and 2 of Section 3.4.2 of the. RCP.,. "Emergency Procedure for Nuclear Criticality atSNM St.orage.~nd EvalU!!tion.fac.iJity (Bldg. 41) or Fuel Process and Development Facility:{Bldg. 39);" state that {1} where a criticality has been verified 1

  • th.e Emergency co*o*rd i na tor wi 11 dee 1are an A1ert with appropriate notification and evaluation of.the potential dose to*the public, and ( 2) within one hour, a dec.i s ion will be made on the necessity for evacuation based on Figures 3.2 through 3.8. Figures 3-2 through 3-7 provide dilution factors based on atmospheric stability conditions for estimating gaseous effluent releases. The _*remaining steps_ in this procdure section of*

the RCP also utilize Figures 3-8,"through ,J.,...10. for estimating offsite doses.

  • The inspector.determine4,:-\~atlhe ~sfim~ted dose;S deJjn~ated in Figures 3.8 through 3-10 .w~re not. valid since tlj_e,,HTGR fuel: Jabricatton fac:il ity' was completely demolished fRr its decom(!!is~ioning. -Additionally,.-the inspector considered these dose estimates to have been non-conservative when the facility was operating. Specifically, the doses would have been greater from a postulated-accident in the operating area of the HTGR,fuel fabric~tion~

facility wher.e* :there was ,no ,.s.pec i~ l,;:5~i eldi ng. .Add it i tma 1ly ~ other._:ons i te,;"'

facilities us,i))g *sNM werf .nol:~pedffral:iy designed to:.mitigate tne consequences of an accidental criticality and no evident,evaluations were2made to demonstrate'.Jhe p9te~~tial off:~it~ consequence? from these facilities. . .

Currently there are three fa~ilHies that are actively or sporadically involved in operations where '.more than :a critical mass of U-235 can be present, These facilities are: (1) the TRIGA fuel fabrication facility 1ocated in Bu,ildi ng .22 pn the., Mai-n SiteJrftQrrey Pines Mesa), {2} the .Modular Helium Reactor (MHRJ. pi*lot,\foel proces,s, lotZated i.l'.l Building ~9:at: the:Sorrento Valley site, and (3) the SNM storage vault located in Building 41 at the

Sorrento Valley site. These facilities, respectively, are approximately 30 meters, 90 meters, and 110 meters from the site boundary fence line.

The inspector also noted that Figure 1-1, "Location of nearby industrial parks and community facility," dated 1975, and Figure 1-2, "Plan View of Site, " not dated in the August 1992 RCP and the recently submitted June 1994 RCP, do not reflect the current industrial growth adjacent to the licensee's facilities.

During the past several years, the licensee has sold large portions of property adjacent to the main site for industrial use. A large portion of the sold property on the west side of the main site is now occupied by office buildings and other industrial facilities, and the land sold on the north and northeast side of the main site and in close proximity of the TRIGA fuel fabrication faci l ity has been prepared .for the occupancy of industrial facilities. The industrial facilities adjacent to the licensee's Sorrento Valley facilities **has also increased *over the years. Many -of these facilities are approximately 150 to* 200 meters from the licensee's site boundary . fen*ce 1 ine.

The above observations were discussed with cognizant l icensee personnel during the inspection and at the exit interview on September 9, 1994. The licensee representatives acknowledged that the estimated offsite doses delineated in Figures 3-8 through 3-10 could be non-conservati ve in cont emplating potential consequences of a postulated criticality accident from existing facilities.

The inspector acknowledged licensee comments that activities involving the use of SNM and the production, of. TRiGA

  • and MHR
  • fuel have been *l imited
  • and *that it was unlikely for an*accidental criti cility to occur relative to these operations . The inspector r_e ferred the licensee to 10 CFR 70.22{i){l) regarding requirements for evaluations .

During the inspection and at the exit interview on September 9, 1994, The licensee acknowledged the need to perform the *subject eva 1uations and update the figures in the RCP to illustrate nearby industrial facilities. During a telephone conversation between the Director, licensing, Safety and Nuclear Compliance afldthe Chief, Materials: Branch -and-the ,i nspector on September .14, ,_ ..

1994, the license*~:*representative',,.nated that a' plan of the lic~nsee's:"f : *:~-'

approach and schedule for performing the *- subject evaluations would be ..

submitted to tfie NR~ Region IV staff by Oi:toberi_-14, 1-994.

The above observations indicate* a lack of attention to detail during the licensee's review *a1id updating-of,the RC.P *-ancf ~r.e vfewed- as a weakness . in the*

licensee's prog-t-alii: The i nspectot:* noted tn'a t ' the 1i ten see' s procedures appeared adequate"" for estimating p_o tenti al offsite consequences from fires, explosion or othe*r ~t:onditi<>"ns tha-t:,have t-he potential for: an accidenta-l release of radioactive mater-iais.,** -

2 MINTENANCE AND~SURVEILLANCE TESTING_(88"025)

This area was

  • re*iiewed-t9-*:determine-:that':'the* gener:al_ ma:intenance of equipment was evident,' and s*u*rvei1Ya'nce tests were- heing fer*formed in accordance with

the license and that safety related equipment was being adequately maintained.

Due to limited onsite activities, safety related equipment primarily involves that for fire protection, control of radioactive material, personnel safety, and emergency preparedness.

The inspector noted that tags indicating recent quarterly air flow tests of operating hoods and/or equipment enclosure openings indicated that air flows were within the limits specified in the license. Exhaust ventilation systems were observed to be operating in all of the areas toured as indicated by differential pressure and other similar gauges.

Selected records of tests and inspections of fire protection systems for the past year were reviewed and di.scussed _.with the Supervisor, Emergency Services.

Fire sprinkler system :flow tests were . perfor,med -monthly and full flow tests on the fire main were performed semiannually.* Fire extinguishers *were also being checked month_ly. Calibration records . demonstrated that the scram system for the uranium-zirconium fines burn furnace in

  • the TRIGA fuel fabrication facility was being calibrated at six month intervals in accordance with licensee procedures.

The inspector concluded that safety related equipment was being adequately maintained and ..no *safety concerns were identified .

3 .CRITICAdrv.'sAFETY) .RADIATION SAFETY, AND- OPERATIONS REVIEW (8801~. ~3.822., AND 88020) .

There had been .no changes since the previous inspection (Inspection Report 70-734/94-01} of these program areas. The inspection

  • of these areas during this inspection -(70-734/94-.03) was ba~ed on observations made during facility tours and di*.s<:_uss i*ons with . 1i censee* personne1.. .. . .

The inspector .nQted that there were no current activities involving the use of SNM at the M~R .::f~el p-.ilot_plant ,facility. The licensee informed the inspector that there may be a smal_l project in October 1994 to coat ready made fuel particles for a forelgn company.

  • No other projects-;involving the *use of SNM were expected for the remainder of thi;: year. Regarding ,,the TFFF; *the-Jicensee was in the process of fabricqting 30 TRIGA reactor _fuel !elements *which.

commenced in mid July *1994 . .*There had. been no :other-.fuel .fabrication projects since January 1994 *., .Th~ ,l i.cen.s ee eXpl:lcted ~o/*t qmplete nthis project by. mid ~-

October 1994. The inspector noted that *posting,_:of criticality *safety limits at each work station and_sthe.-_ use of -SNM -wer.e in,:-accordance with .-.the licensee's criticality safety analyses and license conditions. Sealed SNM storage containers were adequately labeled with .the uranium content *and enrichment. ,11 During facility tours, the rinspector noted that radioactive materials *and radiation areas were posted in accordance with the requirements delineated in 10 CFR Part 20. The in*speeto:r observed th.at-wo~kers.:~ere . dressed dn ,.. !l<;-:.;1 protective clothing as specified in tme respective facility work ii.

authorization. Radiation survey instruments utilized in the field were within their current calibration period.

No safety concerns were identified by the inspector.

4 FOLLOWUP (92701)

(Closed) *Inspection followup Item 70-734/9402-01: Review of licensee's evaluation of radiation exposure to members of the public and personnel in controlled areas.

Based on the review of the licensee's evaluation of accessibility and potential radiation dose to members of the public from certain site locations (site boundary fence line behind Building 27-1 and the Sorrento Valley High Leve 1 Waste Storage ,faci'l Hy} and the -review of the *licensee* s 1994 second quarter environmental thermoluminescent dosimeter (TLO} readings, the inspector concluded that the licensee's evaluation appeared adequate . The licensee's evaluation demonstrated that no individual could have received a radiation dose in excess of the limits 10 CFR 20.1301 and 49 CFR 190.

Regarding the evaluation of the radiation dose to non-radiation GA workers who worked in Room 106 adjacent a SNM storage room in Building 41, the inspector concluded that the licensee had not diligently evaluated this matter.

Specifically, -the licensee had received -and reviewed the .vendor's second quarter TLD results :*on-;Augu.st: 9., 1994, and had be~n ;-pe:rf:or.m.i ,ig r.outi-ne monthly radiation surveys (micro*:R meter) in Room._106 * . :Howe_ve:r,- -.~.s ,Qf t.he.. mornjn_g of September 7, ,1994/* the* 1icensee had not ca1culate(l. the, idQ:s~. to !ind:lvi.dua1s of concern. Followi~g the inspector's questirining the doses of these individuals, the health physics manager (HPM) subsequently provided the inspector with art evaluation later in the day. The evaluation stated that the highest dose received (individual A} was 10 mrem based on .40% occupancy_for the 1994 second quarter and a total of 23 mrem from January 1 through :June 30.

1994. The inspector made the following observations relative to the licensee's evaluation: --

  • During the inspector's interview w1th individuals working in and adjacent to Room 106, individual A stated that he had worked in Room 106 approximately 90% of each work week during the second quarter of 1994.

The discrepancy of occupancy time *was discussed with the HPM and the Health Physics technician (HPT) assigned to the area. The HPT stated that he had not interviewed individual A and assumed that a previously evaluated occupancy time of 40% had not changed.

  • The vendor's second quarter dosimetry report indicated no measurable dose for TLD 9461 (located in the center of Room 106 and previously used for the dose assessment) while the TLDs attached on the wall adjacent to the SNM vault indicated slightly higher doses than the 1994 first quarter readings. The vendor's second quarter report for TLD 9461 also showed a start date of July 1, 1994. During an examination of the TLO

9461 station, the inspector noted that the second quarter TLD had not been exchanged. The involved HPT stated that apparently he had mistakenly placed the third quarter TLD with those exchanged for the second quarter. During the HPM's review of the vendor's TLD report on August 9, 1994, the anomaly of TLD 9461 indicating no dose and a new start date of July l, 1994, was not questioned.

  • The inspector noted that the TLD dose used in the licensee's evaluation was from TLD 9468 which had been attached to the Room 106 wall that separates the SNM storage facility. Subsequent discussions with the HPM revealed that TLD 9468 was mistakenly assumed to be the one (TLO 9461) normally used for the middle of the room without comparing the TLD number with the mapped location. The HPM informed the inspector during the inspection and at the exit interview that the individual A's dose would be re-evaluated and the evaluation sent to the RIV Field Office for the inspector's review.

Although the individuals who performed tasks in Room 106 had not previously been considered radiati.on workers, on September B, 1994, the licensee c1assified the dose received by these individuals to be an occupational dose because their assigned duties involve exposure to radiation, and the resultant dose may exceed 100 mrem (Reference, Answer to Question 26(b), NUREG/CR-6204).

The licensee was making arrangements to relocate radi~active materials in the SNM storage vault to: k~ep .the d.ose *to* i ndi vidua1s 'i:n* ,Room ,106 AtARA:.: -

  • Additionally, the li~ensee was cons-idering adding shielding and the possibility of relocating the activities in Room 106 to another onsite facility.

By facsimile on September 22, 1994, the licensee provided the inspector with a rev i sed comprehensive ev a1uat ion of the dose ,to the workers .; n Room 106-.' The licensee's evaluation concluded that individual A was receiving app~oximat~ly 20 mrem per quarter and another person averaged approximately 14 mrem per * *

  • quarter.* Th\:!J.nsp~ctor had no further. questions regarding th,is,;matter and no -

violations werli!:identified. - * *  ::: - -:*,:-

ATTACHMENT 1 PERSONS CONTACTED 1.1 Licensee Personnel

    • K. E. Asmussen, Director, Licensing, Safety and Nuclear Compliance
  • J.M. Brock. Supervisor, Emergency Services
  • R. K. Kruger, Manager, TRIGA Fuel Fabrication
  • B. Laney, Licensing Engineer
  • H.J. Lomax, Construction Planner, Facilities Engineering.
  • V. Malakhof, Manager, Nuclear Safety
  • R. C. Noren, Director, Nuclear Fuel Fabrication
  • L . R. Quintana, Manager, Health Physics R. Tadesse, Health Physicist
  • C. L. Wisham, Manager, Nuclear Materials Accountability
  • J. Yi, Deputy Manager, Nuclear Safety In addition to the .individuals noted above, the inspector contacted other personnel during this inspection.
  • Denotes those attending the exit interview on September 9, 1994 .
  1. Denotes telephone conversation on September 14, 1994.

2 EXIT INTERVIEW On September 9, 1994, the inspector met with the licensee representatives to discuss the scope and findings of the inspection. The 1icensee*-*was informed of the observations described in the report.

The Director, Licensing , Safety and Nuclear Compliance agreed that u,*e *Rc*p needed to be updated and committed to re-evaluating the potential offsite radiological consequences due to an accidental criticality event consistent with current operations , and submitting a revised RCP to inc.l ude the *results of their evaluations and updated Figure 1-1 to reflect the growth of current industry near GA's facilities. Additionally the Manager, Health Physics committed to sending the inspector a re-evaluation of the radiation dose to individuals who had worked in Room 106 of Building 41. This. _i;l£t,iQn __was * "'

  • completed on September 27, 1994.

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,1-tq SPECIFY ALL THAT APPLY

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