ML20286A314

General Atomics SNM Inspection Report and NOV 070-00734, 1999-03

ML20286A314
Person / Time
Site:	07000734
Issue date:	02/19/1999
From:	Chamberlain D Division of Nuclear Materials Safety IV
To:	Edwards J General Atomics
References
IR 1999003
Download: ML20286A314 (23)

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NUCLEAR REGULATORY COMMISSION REGION IV

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J. Edwards, Vice President General Council and *secretary General Atomics P.O. Box 85608 611 RYAN PLAZA DRIVE. SUITE 400 ARLINGTON. TEXAS 76011-8064 FebnJary 19, 1999 San Diego, California 92186-9784

SUBJECT:

NRC INSPECTION REPORT 70-734/98-03 AND NOTICE OF VIOLATION

Dear Mr. Edwards:

On January 15, 1999, the NRC completed an inspection at your Torrey Pines Mesa and Sorrento Valley facilities. The inspection was conducted on December 7 -11, 1998 and January 11-15, 1999. A telephone followup exit briefing was conducted on February 19, 1999. The enclosed report presents the scope and results of that inspection.

Areas examined during the inspection included management and organizational changes, radiation protection, training, and the operations portions of your site decommissioning activities. Inspection activities consisted of selective examinations of procedures and representative records, interviews with personnel,* and observation of activities in progress. The inspection also included confirmatory surveys on portions of Buildings 21 and 39, the hot cell facility area (former Building 23) and the Torrey Pines West land area.

Based on this inspection, activities conducted at the Torrey Pines Mesa and Sorrento Valley facilities were generally characterized by implementation of effective programs for decontamination and decommissioning. However, based on the results of the inspection, the NRC has determined that one violation of NRC requirements had occurred.

The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding this violation are described in detail In the subject inspection report. The violation occurred because the confirmatory survey performed at your Building 21 by the inspectors identified one area of contamination that was not surveyed as required and exceeded the NRC approved criteria for release to unrestricted use. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice of Violation when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 1 O CFR 2. 790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room (PDR).

ML20286A314

General Atomics Should you have any questions concerning this inspection, please contact D-Blair Spitzberg at (817) 860-8191 or Wayne Britz at ((817) 860-8194.

Docket: 70-734 License: SNM-696

Enclosures:

NRC Inspection Report 70-734/98~03 Notice of Violation cc w/enclosure:

Dr-K. E. Asmussen, Director Licensing, Safety and Nuclear Compliance P.0. Box 85608 San Diego, California 92186-9784 Sincerely,

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Division of Nuclear Materials Safety California Radiation Control Program Director

General Atomics E-Mail report to Document Control Desk (DOCDESK) bee w/enclosure to DCD (IE07) bee w/enclosure distribution by RIV:

RIV Regional Administrator DDChamberlain LLHowell DBSpitzberg MRShaffer WLBritz MIS System FCDB RIV Materials Docket File (5 th floor)

EMcAlpine, All PLHiland, RIii CWEmeigh, FCLB/NMSS (803)

CEGaskin, FCLB, NMSS (8D11)

PTing, FCOB/NMSS (8A 13)

PHarich, FCOB/NMSS (8A33)

DOCUMENT NAME: Draft: G:\\fcdb.o\\wlb\\8073403.wlb Final: R:\\_dnms\\8073403.wlb To receive copy of document, Indicate In box: "C" = Copy without enclosures *E* = Copy with enclo, RIV:DNMS:FCDB LCCarson I1:wsw u,

02/199 OFFICIAL RECORD COPY

General Atomics San Diego, California NOTICE OF VIOLATION Docket No.:

70-734 License No.: SNM-696 Du ring an NRC inspection conducted on January 7 -11, 1999, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, Revision 1, the violation is listed below:

Sat ety Condition S-1 of License SNM-696 authorizes the use of the Site Decommissioning Plan dated October 11 and December 5, 1996; April 18, 1997; and January 15, 1998.

Safety Condition S-16 of License SNM-696 states: "Release of equipment, facilities, or packages to the unrestricted area or to uncontrolled areas onsite shall be in accordance with the attached "Guidelines for Decontamination of Facilities and Equipment P_rior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated April 1993. The guidelines for decontamination of beta/gamma emitters in the attached document are 5,000 dpm/100 cni2 average, 15,000 dpm/100 cm2 maximum and 1,000 dpm/100 cm2 removable.

Section 6.1.1, "Release of Items and Equipment," of the Site Decommissioning Plan states, in part: "If the potential exists for contamination on inaccessible surfaces, the equipment will be assumed to be internally contaminated unless (1) the equipment is dismantled allowing access for surveys, (2) appropriate tool or pipe monitors with acceptable detection capabilities are utilized that would provide sufficient confidence that no licensed materials were present,.... " Section 6. 1.3,.. Description of Final Radiation Survey Plan," states: "Once all identified affected areas are evaluated and cleaned up as necessary, a final radiation survey must be performed to demonstrate compliance with the release criteria."

By letter dated November 2, 1998, the licensee requested the NRC to release office areas of Building 21 to unrestricted use and delete them from the license. To support this request, the licensee submitted with the letter the report, "Final Radiological Survey Performed at General Atomics' Building 21 Unaffected Office Areas," dated November 2, 1998. The November 2 letter stated in part, The results of GA's extensive and comprehensive final radiation and contamination surveys, measurements, sampling, and analyses demonstrate conclusively that the unaffected office areas of its Building 21 meet the NRC approved criteria for release to unrestricted use."

Contrary to the above, a confirmatory survey performed by the NRC inspectors on January 13, 1999 identified contamination exceeding-the release criteria in the office areas of Building 21 on an inaccessible surface with potential to be internally contaminated. The contamination consisted of a "hot particle" in the drain pipe of the Building 21 office area janitor closet. The final survey report of the licensee showed no surveys were performed from within this pipe as required. The particle was tater analyzed by the licensee to measure 100,000 counts per minute on contact and to consist principally of Cesium-137, a beta/gamma emitter.

This is a Severity Level IV violation. (Supplement VI)

Pursuant to the provisions of 1 0 CFR 2.201, General Atomics is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, within 30 days of the-date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a

~Reply to a Notice of Violationu and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Jf you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material,, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 1 O CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 1 O CFR 73.21.

Dated at Arlington, Texas this 19 th day of February 1999

Docket No.;

License No.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Accompanied by:

Approved By:

Attachment:

U.S. NUCLEAR REGULATORY COMMISSION REGION IV 70-734 SNM-696 70-734/98-03 General Atomics Torrey Pines Mesa and Sorrento Valley Facilities San Diego, California December 7-11, 1998 and January 11-15, 1999 Louis C. Carson II, Health Physicist Wayne L. Britz, Fuel Cycle Inspector D. Blair Spitzberg, Ph.D., Chief, Fuel Cycle/Decommissioning Branch Division of Nuclear Materials Safety D. Blair Spitzberg, Ph.D., Chief, Fuel Cycle/Decommissioning Branch Division of Nuclear Materials Safety Supplemental Information EXECUTIVE

SUMMARY

General Atomics (GA)

NRC Inspection Report 70-734/98-03 This routine, announced inspection focused on management and organizational changes, radiation protection, training, operations and validation of portions of the licensee's final radiological survey program for site decommissioning activities. Specific attention was given to decommissioning activities involving Building 21 (TAIGA Reactor Facility), Building 39 (Sorrento Valley "B" building), the hot cell facility area (former Building 23) and Torrey Pines West (a land area near the Building 30/31 complex).

Decommissioning Inspection Management Organization and Controls The licensee's management and staff changes were found to be in compliance with the requirements contained in the license and the Site Decommissioning Plan (SOP)

(Section 1.1).

Radiation Protection The licensee had implemented a radiation protection program that was found to be in accordance with the license and 1 O CFR Part 20. Areas of the radiation protection program that were reviewed and found to be acceptable included radiation work permits (RWPs), airborne radioactivity sampling, and the sealed source leak detection programs (Section 1.2).

Training Training requirements of the license and SDP had been met. Training instructors met qualification requirements. (Section 1.3).

Operations The licensee's inventory and storage of special nuclear material (SNM), and the testing and deactivation of the criticality alarm system were in compliance with the license conditions and facility procedures (Section 1.4).

Closeout Inspection and Survey Based on the results of this inspection, activities conducted at the Torrey Pines Mesa and Sorrento Valley facilities were generally characterized by implementation of effective programs for decontamination and decommissioning (Section 2.2).

Confirmatory surveys conducted at the Torrey Pines West land area and the designated areas of Buildings 21 and 39 were consistent with licensee measurements with one exception related to a contaminated pipe. The NRC's confirmatory measurements confirmed the licensee's determination that these areas and facilities met the criteria for unrestricted release, except as noted below (Section 2.2).

One violation involving the licensee's failure to perform a survey required by the SDP in License Condition S-1 was identified. The failure to survey resulted in an area of contamination in excess of the guidelines for decontamination required by License Condition S-16 ( Section 2.2}.

The results of NRC split soil sample confirmatory measurem_ents from the hot cell facility area were in good agreement with licensee results. The results of the soil samples taken from downstream of the depression pond at the hot cell facility area were less than the criteria established for unrestricted release (Section 2.2).

The inspectors concluded that the licensee's instruments were calibrated and operated satisfactorily (Section 2.2).

Report Details Summary of Facility Status A:I production and research activities involving the use of special nuclear material (SNM) had been discontinued. The SNM activities are being decommissioned according to the Hot Cell Facility Decommissioning Plan, Rev. 4, dated January 1998, and the Site Decommissioning Plan (SOP), dated September 1996. During a March 20, 1998, meeting with the NRC Fuel Cycle Licensing Branch, General Atomics indicated that it had increased the tempo of decommissioning activities at the site.

At the time of the inspection, licensee activities consisted of decontamination and decommissioning (D&D} of various site buildings and structures as outlined in the two plans.

Following extensive site characterization, several site area:s had been radiologically surveyed for release from the SNM license. D&D was also proceeding for radioactive byproduct materials licensed by the State of California.

The D&D activities were inspected according to Decommissioning Inspection Procedure 88104 and Closeout Inspection and Survey Procedure 83890. Portions of inspection procedures that were applicable during the licensee's operational program and that carry over to the licensee's decommissioning program were selectively used during this inspection as provided for in the Decommissioning Inspection Procedure. The applicable portions of the procedures used were from the Management Organization and Controls Procedure, 88005; Radiation Protection Procedure, 83822; Operator Training/Retraining Procedure, 88010; and Operational Safety Review Procedure, 88020 (Temporary Instruction 2600/003).

Areas reviewed during this inspection which involved D&D of NRG-licensed facilities included:

The Torrey Pines West land area categorized as a "non-impacted" area. The area was never used for work involving radioactive materials or storage of radioactive materials.

Limited surveying and sampling were performed by the licensee to demonstrate compliance with the approved criteria for release to unrestricted use. The licensee made surface and area measurements and collected and analyzed soil samples to demonstrate compliance. Confirmatory surveys were accomplished during this inspection.

Building 21 houses two TAIGA non-power reactors and offices. The office and restroom areas in Building 21 were categorized as "unaffected" areas and were surveyed by the licensee to be released for unrestricted use. The reactor portions of the building will be decommissioned separately. The licensee had conducted surface and area measurements to demonstrate compliance. Confirmatory surveys were accomplished by the NRC during this inspection.

The hot cell facility (former Building 23) had been removed and the ground area was being remediated. As part o'f the ongoing decommissioning process, soil samples were obtained by the licensee and split with the NRC for confirmatory analysis.

Building 39 had been remediated and readied for disposal to either a radwaste disposal facility or a clean landfill disposal facility. The office areas, walls and roof were classified as either "unaffected," "non-suspect affected," or "suspect affected" areas. The licensee made surface and area measurements of the walls, floors, metal roof, roof tar and insulation layers, and analyzed samples of paint, soil, and roof gravel. Confirmatory surveys were accomplished by the NRC during this inspection.

The licensee's possession-only licensed activities and D&D program attributes were previously discussed in NRG Inspection Report Nos. 70-734/98-02 (July, 1998), 70-734/98-01 (January 1998), 70-734/97-05 (December 1997), and 70-734/97-02 (June 1997).

1 Decommissioning Inspection (88104) 1.1 Management Organization and Controls (88104 and 88005)

a.

Inspection Scope The inspectors reviewed and discussed the current health physics organization structure, staffing, functional assignments, and audits to determine compliance with the requirements of the license.

b.

Observations an_d_Eindin~

Recent changes to the current health physics organization were reviewed. The organization and functional requirements are stated in the license's Safeguards Conditions, Section 3.2.2.2, "Health Physics," and Section 3.3, "Position Qualifications and Training," and in the SOP Section 4, "Decommissioning Organization, Training and Methods Used for Protection of Occupational and Public Health and Safety."

The Manager, Health Physics, was on leave during part of the inspection period and was expected to be on leave for a total of about two months. During that time, a senior health physicist had assumed the additional duties of the manager. The qualifications of the senior health physicist were reviewed and found to be adequate. Five additional personnel had been added to the health physics organization for additional decommissioning projects. Their qualifications were reviewed and found to be adequate.

c.

Conclusions The licensee's management and staff changes were found to be in compliance with the requirements contained in the license and the SOP.

1.2 Radiation Protection (88104 and 838-22)

a.

Inspection Scope Portions of the licensee's radiation protection program were reviewed to verify compliance with License Conditions S-6, S-9, and S-10 as well as 10 CFR Part 20.

The inspectors reviewed routine radiological protection activities during the decommissioning inspection and confirmatory survey activities. In particular the inspectors reviewed the radiation work permit, air sampling programs, and testing of sealed plutonium sources for conformance to license requirements.

b.

Observations and Findings License condition S-6 requires, in part, that the licensee issue radiological work permits (RWPs) for all unplanned or non-routine work with licensed material not covered by a work authorization (WA). Additionally, an evaluation of the safety effectiveness of the RWP was required when the work was completed. The inspectors reviewed RWPs that were issued in 1998 and 1999. The inspectors found that the RW Ps included both radiation safety and maintenance work instructions for a given task. The RWPs were found to have contained an adequate level of information about scope of the work to be performed and the corresponding radiological restrictions. The inspectors toured the hot cell facility and the Nuclear Waste Processing Facility (NWPF). Licensed activities in these locations involved work with radioactive materials for decommissioning and waste processing. When the inspectors found radioactive material in a radiologically clean facility, the-licensee issued an RWP to investigate the problem and recover the material [see section 2.2(c)J. The inspectors reviewed several RWP safety effectiveness evaluations and determined that the evaluations were adequate. The inspectors determined that the licensee's RWP program was adequate and met the requirements of License Condition S-6.

License condition S-9 requires, in part, that the licensee maintain continuous air sampling in any area where licensed material can become airborne. The inspectors determined that three areas existed on the site where licensed activities were such that radioactive material_

could become airborne. Those areas were the NWPF, the hot cell facility, and Building 39.

The inspectors found that several high volume continuous air samplers were operating at the NWPF on a 24-hour basis. The licensee operated a beta air monitor with alarm features during specific hazardous operations. The inspectors noted that the licensee operated high volume air samplers at the hot cell and Building 39 facilities during activities that could cause radioactive material to become airborne during a given task. Additionally, the licensee used grab samplers such as air lapel samplers in a continuous monitoring mode. The inspectors determined that the licensee's continuous air sampling program was adequate and met the requirements of License Condition S-9.

License Condition S-10 requires, in part, that the licensee check the location air samplers on an annual basis and whenever any process or equipment changes are made to verify that work area air sampling is adequate. The inspectors found that the licensee had conducted air sample placement reviews in the Sorrento Valley Building, NWPF, and the hot cell facility during 1997 and 1998. The licensee showed the inspectors that the performance of the air sampler reviews was routinely tracked as part of management's "Required Activities List." The inspectors also reviewed internal correspondence regarding air sampler review findings. The inspectors reviewed the completed "Air Sampler Review

forms and noted that not all licensee personnel used the form identified in Procedure No.

45, "Airborne Evaluation." Additionally, Procedure No. 45 did not provide instructions on the criteria to apply during the air sampler review and filling out the form. The inspectors concluded that the licensee met the requirements of license condition S-10; however, guidance for the conduct of the air sampler reviews was weak.

The inspectors reviewed the leak testing performed on sealed plutonium sources. The sealed sources had been leak tested every six months. The plutonium sources that were not in use were stored in sealed containers in the SNM storage area. These sealed containers were inspected. The last leak test was performed in July 1998, and records showed the tests had been appropriately conducted and no leaking sources were identified. The next test was scheduled for January 1999. The licensee was in compliance with the requirements for *testing sealed plutonium sources required by the License Safety Condition S-12 and License Safeguards Condition 4.1.5, "Sealed Plutonium Source Leak Testing."

c.

Conclusions The licensee had implemented a radiation protection program that was found to be in accordance with the license and 1 O CFR Part 20. Areas of the radiation protection program that were reviewed and found to be acceptable included RWPs, airborne radioactivity sampling, arid the sealed source leak detection programs.

1.3 Training (88104 and 8801 O)

a.

Inspection Scope The inspectors reviewed training records and discussed the training provided to the radiation workers onsite for the decommissioning work.

b. Observations and Findin.9§ The inspectors reviewed records for the general employee radiological training (four hours of training), radiological worker training {sixteen hours), emergency response training (one hour), criticality safety training (one hour) and respiratory protection training (two hours).

The training records included the person, date, type of training, test score and the instructor. In 1998 eight radiation worker training classes were provided to twenty-one persons, and eleven classes in refresher radiation worker classes were provided to one-hundred-fifty-four persons. The inspectors found the training to be in compliance with the requirements of License Safety Condition S-7, which requires that radiation safety training be given to all new employees; License Safety Condition S-8, which requires that radiation safety training and indoctrination be conducted by the Health Physics Manager or by a similarly qualified individual; and the SOP, Section 4.4, "Training," which requires training for all personnel working on decommissioning projects.

c.

Conclusion.§ The licensee's training program for radiation and decommissioning workers was found to be in compliance with 10 CFR Part 19, the license, a:nd the SOP.

1.4 Operational Safety Review (88104 and 88020)

a.

Inspection Scope The inspectors reviewed the inventory of SNM, its storage facilities, and the operability of the criticality safety alarms and testing of the alarms.

b. Observations and Findings The inspectors reviewed the inventory list of SNM for compliance with the amounts allowed by the license. The inventory list detailed the specific type of enriched uranium and plutonium. The list also specified the storage location, element weight, isotopic weight and intended disposition. The licensee had planned to dispose of SNM inventory as fuel shipment containers are approved, sales of SNM inventory are made, and other government agencies make arrangements to receive the materials for use or storage. Two storage locations of SNM were inspected. A variety of drums, casks and smaller containers were used to store SNM. Ambient radiation levels were low (less than 1 mrem/hr) in the storage areas. The SNM inventory was found to be in compliance with the licensed amounts. Radiological postings were in compliance. Radiological procedures for entering and exiting the SNM area included personnel monitoring.

The inspectors reviewed the status of the criticality alarm system and testing. Recent decommissioning of facilities had reduced the number of criticality alarm systems in operation. During 1998, the criticality alarm systems in Buildings 22, 23, and 39 had been removed due to decommissioning of the facilities. The alarm system for Building 23 was put in nearby office-trailers when the hot cell facility was removed. The alarm system for the former Building 23 was no longer in operation and will be removed. Criticality alarm systems were currently in operation in Building 21, TAIGA reactors (five detectors);

Building 30, radioactive material storage (two detectors); Building 31, radioactive material storage (two detectors}; and Building 41, waste yard {six detectors). The inspectors reviewed the monthly checks of the criticality alarm systems and documentation tor deactivation of criticality detection and alarm systems. The monthly checks and deactivation procedures were found to be in compliance with the requirements of License Safety Condition S-18; License Safeguards Condition 4.2, "Equipment;" and HP Procedure

1. 4, "Criticality Warning Alarm Deactivation Procedure."

c.

Conclusions The licensee's inventory and storage of SNM, and the testing and deactivation of the criticality alarm system were in compliance with the license conditions and facility procedures.

2 Closeout Inspection and Survey (83890) 2.1 Scope The licensee's preparations, final survey plan, conduct of the final survey, and analysis of the results for selected areas within the Torrey Pines West land area, Building 21 (office and rest room areas), hot cell facility area (soil samples), and Building 39 were reviewed to determine their agreement with the methodologies contained in NUREG-5849, the licensee's SOP, and the requirements set forth in 10 CFR 70.38(j).

Confirmatory surveys for surface alpha, beta and gamma, and ambient gamma radiation exposure levels of selected areas within the aforementioned buildings and areas were conducted by the inspectors to determine the radiological status of the facilities being considered for release by the licensee.

2.2 Observations and Findings

a. Confirmatory Survey Instrument Checks During the confirmatory surveys, NRC inspectors used the following radiation detection instruments: gas-proportional, Geiger-Mueller (GM), alpha scintillation, and a sodium iodide. The inspectors performed calibration and operational checks of NAC radiation instruments. The inspectors compared the performance of the NRC instruments to similar instruments used by the licensee. For the gas-proportional instrument performance comparison, the following National Institute of Standards and Technology (NIST) traceable radiation check sources were used: strontium-90, technetium-99, urani'um-234/235, plutonium-239, and thorium-230. The average alpha/beta efficiency of the NAC's gas-proportional instrument was 24.7 percent and average efficiency for the licensee's instrument was 28.6 percent. Both the licensee and the NRC used strontium-90 as the NIST traceable radiation source for the GM detectors, and the efficiencies were 22.3 percent and 22.7 percent, respectively. The inspectors used a thorium~230 radiation check source for the alpha scintillation detectors. The NRC's detector efficiency was 14 percent, and the licensee's efficiency measured 21 percent. Finally, the inspectors compared the efficiencies of the sodium iodide detectors using the licensee's NIST-traceable cesium-137 radiation source. Both the licensee's and the NRC's detector efficiencies measured 10 percent.

The inspectors determined that the efficiencies of the licensee's radiation detection instruments were equal to or more efficient than the NRC's instruments. The inspectors concluded that the licensee's instruments were calibrated and operated satisfactorily.

b. Torrey Pines West land area The licensee's "Radiological Survey Report for the Release of 'Torrey Pines West' Land Area to Unrestricted Use," dated September 30, 1998, was reviewed and found acceptable. The inspectors performed a confirmatory survey of the Torrey Pines West land area. The survey consisted of alpha, beta and gamma measurements over several portions of the land area. No soil samples were taken. The NRC's ambient radiation measurements at ground level and three feet ranged from 12-16 µR/h. The results were alt equivalent to background values and confirmed the licensee's measurements which demonstrated that the area met the criteria for unrestricted release.

c. Building 21 - TAIGA reactor facility The licensee's "Final Radiological Survey Per1ormed at General Atomics' Building 21 Unaffected Office Areas," dated November 2, 1998, was reviewed and found acceptable.

The inspectors performed a confirmatory survey of the office and rest room areas (the unaffected areas) on January 13, 1999. The survey consisted of alpha, beta and gamma measurements over several portions of the approximately 850 ft2 area. One area around a janitorial sink drain was found to have a contact reading of 50 µR/h. The background radiation value was identified as 15 µR/h. The janitorial sink had been removed and the drain line capped before the inspector's confirmatory survey. The licensee stated that during their survey the pipe was not capped and that all other conditions were the same during the licensee's and NRC's surveys. The inspectors asked the licensee why there was radioactivity in a former office area with no history of use of radioactive material, and why their survey did not report this radioactivity.

The licensee responded with an investigation report dated February 2, 1999, and further telephone conversations. As part of the investigation, the licensee removed an approximate four-inch section of pipe that was threaded into the main drain line which runs vertically behind the waif in the room. The end of the pipe which had been attached to the sink had been capped with a copper fitting that had been.fixed onto the end of the pipe.

The four-inch section of pipe and cap were removed into a radiation controlled area in the same building. At that time the radiation levels at the janitorial sink drain were at background. The licensee's investigation found a thick layer of dried material on the bottom of the pipe (away from the capped end), some of which was loose and some adhered to the inside wall of the pipe. Further analysis found one particle, approximately three millimeters in diameter, having a direct radiation reading of 100,000 counts per minute, was the sole source of the activity. The analysis also determined the isotopic mixture of cesium-137 and cobalt-60 with an activity ratio of approximately 400/1. This ratio had normally been 10/1 on studies the licensee performed on fission product releases from fuel in the building during its operation: The licensee stated this indicated the particle was approximately twenty-five to thirty years old. The licencee also stated it is probable the particle was transported from the building's controlled areas when research on fuel was conducted in the building.

The licensee's investigation concluded that the particle in the pipe may have been disturbed between the time of the licensee's survey and the inspectors' survey by the force applied during the installation of the cap on the pipe. The licensee stated this may have altered the shielding of the wallboard and pipe between the two surveys preventing their detection of the particle.

Safety Condition S-16 of License SNM-696 states: "Release of equipment, facilities, or packages to the unrestricted area or to uncontrolled areas onsite shall be in accordance with the attached "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated April 1993. The guidelines for decontamination of beta/gamma emitters in the attached document are 5,000 dpm/100 cm2 average, 15,000 dpm/100 cm2 maximum and 1,000 dpm/1 oo cm2 removable. The area of contamination in the pipe was determined to be 100,000 cpm. When corrected for detector efficiency the contamination in units of dpm would be higher and in excess ofthe guidelines for decontamination The licensee's SOP, Section 6.1.1, "Release of Items and Equipment," states, in part: "If the potential exists for contamination on inaccessible surfaces, the equipment will be

~ assumed to be internally contaminated unless (1) the equipment is dismantled allowing access for surveys, (2) appropriate tool or pipe monitors with acceptable detection capabilities are utilized that would provide sufficient confidence that no licensed materials were present,.... " Section 6.1.3, "Description of Final Radiation Survey Plan," states:

"Once all identified affected areas are evaluated and cleaned up as necessary, a final radiation survey must be performed to demonstrate compliance with the release criteria."

The licensee*did not perform the pipe survey as it was not identified in the "Final Radiological Survey Performed at General Atomics' Building 21 Unaffected Office Areas,"

dated November 2, 1998. The licensee's letter submitting the survey report stated: "The results of GA's extensive and comprehensive final radiation and contamination surveys, measurements, sampling, and analyses demonstrate conclusively that the unaffected office areas of its Building 21 meet the NRC approved criteria for release to unrestricted use."

The inspectors concluded that the failure to survey the pipe as required by the SDP is a violation of Sat ety Condition S-1 of the license which authorized the use of the SOP. The failure to survey resulted in the licensee failing to identify an area of contamination in excess of the guidelines for decontamination required by License Condition S-16 (70-734/9803-01 ).

d. Hot cell facility area (former Building 23)

Building 23 has been removed and the ground area was being remediated.

Three soil samples were obtained and split for analysis by the licensee and the NRC as part of the confirmatory survey process during decommissioning. One soil sample,

1. 230-98-31 B, was taken from the bottom of a depression pond where effluent water was held up prior to sampling and discharge and two samples, #230-98-298 and #230-98-308, were taken downstream of the depression pond. The comparison results of the licensee's analysis with the NRC's analysis of the soil samples, as presented in the following tables, were all in agreement when compared with the criteria in Inspection Procedure 84525, "Quality Assurance and Confirmatory Measurements."

(Table starts on nex1 page.)

Acceptance Criteria 1 Resolution2

<4 4-7 8

• 15 16

• 50 51 - 200

>200

'Criteria lrom Inspection Procedure 84525, Quality Assurance and Confirmatory Measurements for In-Plant Radiochemical Analysis 2 Resolution is the NRC result divided by its associated 1 cr uncertainty.

3 Ratio is the licensee result divided by NRC result.

Ratio3 0.4 -2.5 0.5

• 2.0 0.6-1.66 0.75-1.33 0.80

• 1.25 0.85-1.18 Soil Sample Analysis Comparison Hot Cell Facility Sample#/

GA Analysis NRC Analysis Resolution 1 Ratio1 Isotope pCi/gram pCi/gram +/- 1 cs

1. 230-98-29B Downstream of Depression Pond Cs-134 0.17 0.23 +/-.06 3.8 0.74 Cs-137 3.7 3.71 +/*.22 17 1.0 Co-60 0.27 0.32 +/-.051 6.3 0.84

1. 230-98-30B Downstream of Depression Pond Cs-134 0.18 0.25 +/-.05 5

0.72 Cs-137 3.7 3.89 +/-.19 20 0.95 Co-60 0.24 0.28 +/-.056 5

0.86

1. 230-98-318 Bottom of Depression Pond (Hold-up pond)

Cs-134 14 14.1 +/-.705 20 0.99 Cs-137 320 360+/-18 20 0.89 Co-60 22 21.5 +/- 1.1 20 1.02 1Resotution, ratio and agreement status determined from above criteria.

Agreement1 Status OK OK OK OK OK OK OK OK OK The results of the soil samples taken downstream after effluents were released from the depression pond were less than the criteria for release of property for unrestricted use.

e. Building 39, fuel process dev.elopment facility The licensee's "Final Radiological Surveys of Selected Portions of Building 39 (SVB) to be Released to Unrestricted Use," dated December 9, 1998, was reviewed and found acceptable except for some editorial items which have been clarified with the licensee.

The inspectors performed a confirmatory survey of the office area concrete floor and associated structural walls (-4,700 ft2), the metal roof over the office area (-4,700 ft), the gravel removed from the roof, and the tar and insulation removed from the roof. The areas were designated as a combination of unaffected areas, non-suspect affected areas and suspect affected ar.eas as described in the licensee's survey report. The survey consisted of alpha, beta and gamma measurements over several portions of the floor, roof, walls, and roof materials. Biased surveys were made in the areas that were designated as non-suspect affected areas and suspect affected areas. The east end of the matrix room was included in the areas to be released as unrestricted; however, the licensee had since decided that all of the matrix room would be treated as radwaste and had painted the area red. Thus, the inspectors did not survey the matrix room. The NRC's ambient radiation measurements of the floor and roof area at the surface and three feet above ranged from 16-20 µR/h.

The designated areas of Building 39 to be released were found to be at background and confirmed the licensee's measurements which demonstrated that the area met the radiation level criteria for unrestricted release.

2.3 Conclusion Based on the results of this inspection, activities conducted at the Torrey Pines Mesa and Sorrento Valley facilities were generally characterized by implementation of effective programs for decontamination and decommissioning.

The inspectors concluded that the licensee's instruments were calibrated and operated satisfactorily.

Confirmatory surveys conducted. at the Torrey Pines West land area and the designated areas of Buildings 21 and 39 were consistent with licensee measurements with one exception related to a contaminated pipe which was later removed. The NAC's confirmatory measurements confirmed the licensee's determination that these areas and facilities met the criteria for unrestricted release.

One violation involving the licensee's failure to perform a survey required by the SOP in License Condition S-1 was identified. The pipe survey was not performed as required by the licensee because the i'nspectors' confirmatory survey determined there was one area of radioactivity in the building that was required by the SDP to be surveyed. This resulted in a contamination area in excess of the guidelines for decontamination required by the license.

The results of NRC split soil sample confirmatory measurements from the hot cell facility area were in good agreement with licensee results. The results of the soil samples taken from downstream of the depression pond at the hot cell facility area were less than the criteria established for unrestricted release.

3 Meeting with State of California On December 8, 1998, NRG staff from the Fuel Cycle Licensing Branch, Office of Nuclear Material Safety and Safeguards (NMSS) and Region IV staff met with State of California staff at the GA site to discuss decommissioning activities related to GA's current accelerated D&D program. GA intends to terminate its SNM license from NRG and reduce its source and byproduct material usage licensed by the State in the next two years. The meeting was requested by the State.

The subjects of the discussion were:

1. The scope of NRG's confirmatory surveys;

2. The criteria the NAG will use to release GA's facilities for unrestricted use, and for continued regulation under GA's California Radioactive Materials License;

3. The role of other agencies such as the Department of Energy (DOE) and contractors such as Oak Ridge Institute of Science and Education (ORISE) in the decommissioning and confirmatory survey processes;

4. The jurisdiction of respective agencies over contamination resulting from GA's various activities involving SNM, byproduct material, and byproduct material from SNM activities onsite; and,

5. The recent incident involving the shipment of waste containing SNM as byproduct m*aterial to the State of Washington. (The incident resulted in radioactive contamination on the truck and land area.}

In regard to confirmatory surveys, NRC and State staff described their confirmatory radiological survey approaches. In general, NRC's and the State's survey programs are similar. It was agreed that for building and land surveys, either NRC or the State, dependent on the nature of contamination, will take the lead to conduct the confirmatory surveys to minimize duplicative efforts. In this effort, NRC and the State will coordinate with each other. After the confirmatory surveys, NRC will inform the State of its licensing action to ensure that buildings can be released for unrestricted use in a timely manner as requested by GA.

The NRC will continue to use NRG Regulatory Guide 1.86 criteria for the release of buildings with surface contamination. For land area released to unrestricted use, the

. criteria developed by the NRG in 1985 and accepted by GA are still valid since these criteria are generally more restrictive than the NRC's 25 mrem/yr limits.

The NRC staff informed the State that ORISE will not be used as NRC's contractor to conduct radiological confirmatory surveys iri the hot cell facility since DOE used ORISE to perform radiological surveys in the hot cell facility D&D program. In addition, it will be unlikely that ORISE will be used to pertorm NRC's confirmatory surveys related to GA's other D&D activities. (Note: DOE contracted with GA for research at the hot cell facility and is funding a portion of the D&O.)

In regard to item 4 and 5, the NRC staff asked the State to send NRC a letter requesting NRC's legal clarification related to jurisdictional questions over byproduct material contamination that may have come from NRG licensed SNM activities versus State licensed byproduct material activities.

In regard to the above referenced item 5 issue, the State agreed to assume the lead for followup.

After the meeting, NRG staff met with GA staff to inform them of the subjects discussed.

NRC staff also toured some of. the GA buildings and areas subject to decommissioning.

4 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of each of the two inspection periods on December 11, 1998 and January 15, 1999. A telephone followup exit briefing was conducted on February 19, 1999, to discuss the violation determined from further investigation after the onsite exit meeting.

The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.

ATTACHMENT Licensee SUPPLEMENTAL INFORMATION PARTIAL LISTOF PERSONS CONTACTED Keith Asmussen, Director, Licensing, Safety and Nuclear Compliance 1* 2 George Bramblett, Project Manager, GA D&D 1* 2 Fritz Dahms, Project Manager, GA D&D 2 Laura Gonzales, GA Radiation Safety Officer/Health Physics Manager John Greenwood, Principal Investigator, TAIGA 2 Barbara Hunter, Health Physics, Hot Cell Facility William LaBonte, Lead Health Physicist, Hot Cell Facility 1

2 Brian Laney, Licensing and Compliance 2 Paul Maschka, Senior Health Physicist 1*2 Bob Noren, Manager, GA D&D 1. 2 John Turner, Health Physics 2 Chester Wisham, Manager, Nuclear Material Control and Accountability 1 Present at exit meeting December 11, 1998 2 Present at exit meeting January 15, 1999 State of California From Sacramento:

Edgar Bailey, Chief, Radiologic Health Branch Donald Bunn, Chief, Inspection, Compliance and Enforcement Unit David Wesley, Chief, Sealed Source & Device/Financial Surety (Projects) Unit Ronald Ragus, Ph.D., Health Physicist, Sealed Source & Device/Financial Surety (Projects) Unit Lisa Brown, Health Physicist, Radiological Assessment Unit From Santa Ana:

Kathleen Henner. Chief, Region 5 Inspection Office Barbara Hamrick, Health Physicist, Region 5 Inspection Office IP 83822 IP 83890 IP 84525 IP 88005 IP 88010 IP 88020 IP 88104 INSPECTION PROCEDURES USED Radiation Protection Closeout Inspection and Survey Quality Assurance and Confirmatory Measurements Management Organization and Controls Operator Training/Retraining Operational Safety Review (Tl 2600/003)

Decommissioning Inspection

Opened 70-734/9803-01 Closed Discussed ITEMS OPENED, CLOSED AND DISCUSSED VIO Contaminated material found in decontaminated area to be decommissioned. Required survey not performed.

None None

CPM D&D DPM ft2 GA GM HCF

~A/h NIST NWPF OR/SE 1a pCi/gram PDR AWP SOP SNM WA LIST OF ACRONYMS USED counts per minute decontamination and decommissioning disintegrations per minute square foot General Atomics Geiger Mueller hot cell facility micro Roentgen per hour National lnstitute*of Standards and Technology nuclear waste processing facility Oak Ridge Institute of Science and Education one standard deviation pico Curies per gram Public Document Room radiation work permit Site Decommissioning Plan special nuclear material work authorization