ML20247A219

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Insp Rept 70-0734/89-01 on 890227-0303.No Violations Noted. Major Areas Inspected:Mgt Organization & Controls,Operator Training & Retraining,Criticality Safety,Operations Review, Transportation & Radiation Protection
ML20247A219
Person / Time
Site: 07000734
Issue date: 03/20/1989
From: Brock B, Brown G, Rish R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20247A206 List:
References
70-0734-89-01, 70-734-89-1, NUDOCS 8903290071
Download: ML20247A219 (14)


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U.2S. NUCLEAR lREGULAT0f8 COMMISSION'

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~ 70-734/89-01 Report No.

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

' Priority 0 Category II Safeguards Group I Licensee: General Atomics P. O. Box 85608

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San Diego, California' 92138.

Facility Name: Torrey; Pines' Mesa'and Sorrento Valley Sites Inspection at:

San Diego, California n

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Ins'pection Conducted:

February 27-March 3',

1989=

Inspector:'

A B. L. Brock, Fuel Facilities Inspector.

Da'te - Si gned.

Inspect'or:

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.G. A. Brown, Emetgency-Preparedness Date Signed ~

l Analyst:

. Approved by:

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N-I R. F. Fish, Chief.

06te signed Emergency Preparedness' Sectio'n Summary:

INSPECTI0'N ON FEBRUARY 27-MARCH-3, 1989 (REPORT ~NO.-70-734/89-01)

A routine.unan'ounced ' inspection was conducted covering.

Areas Inspected:

n follow-up on inspector identified items, management organization and controls, operator training.'and retraining,, criticality safety, operations review, maintenance and surveillance testing, radioactive waste management management, transportation, radiation protection, emergency. preparedness, and '

' environmental programs.

.During this inspection, Inspection Procedures 88005, 88010, 88015,188020,;

88025, 88035, 86740, 83822,: 88050 and 88045 were covered.

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. Results: The effectiveness of the licensee's radiological contingency plan needs to be demonstrated in a fully integrated exercise.

Performance in the area of management' oversight appeared to need strengthening in the area of air flow meter calibrations'and sign off on Radiation Work Procedures and Work

' Authorizations where conditions are. imposed.

Additionally, the licensee needs to give continued close attention to the verification of the initial and continued presence of the neutron absorber essential to the safe operation of the coater wit.h its' increased _ batch size.

Detail is provided in the L

appropriate sections of the report.

No violations were identified in the ten l'

areas inspected.

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DETAILS 1.

Persons Contacted

  • R. N. Rademacher, Vice President, Human Resources
  • K. E. Asmussen, Manager, Licensing Safety and Nuclear Compliance
  • V. Malakhof, Manager, Nuclear 1 Safety
  • R. C. Noren, Director, Nuclear Fuel Fabrication
  • K. L. Johnson, Manager, Facilities Engineering

'* W. L. Whittemore, Manager, TRIGA Reactors Facility

  • J. Razvi, Deputy. Manager, TRIGA Reactors Facility
  • A. L. Galli, Manager, Security R. DeVelasco, Staff Engineer, Core Engineering G. P. Conners, Manager, Reactor Quality Assurance P. Warner, Manager, Fuel Operations, Production & Material Control
  • L. R. Quintana, Manager, Health Physics l

P. J. Niccoli, Superintendent, Facilities Maintenance J. Narvaez, Supervisor, Nuclear Waste Processing Facility E. D. Weldon, Foreman, Quality Control Laboratory

  • L. Adelman, Health Physics Technician S. Perlman, Health Physics Technician l

J. S. Greenwood, Senior Scientist, Hot Cells W. E. Simpson, Senior, Technician N. J. Brown, Manager, Equipment Engineering Branch l

T. W. Keim, Senior Nuclear Fuel Waste Processor B. Evans, Nuclear Waste Control Operator l

  • R. Kreuger, Manager, Triga Fuel Fabrication Facility l

J. Brock, Supervisor, Emergency Services U. Overton, Senior Nuclear Fuel Waste Processor G. Kozumi, Senior Operator i

F. Rustay, Shift Supervisor

  • Denotes those attending the March 3, 1988 exit interview 2.

Follow-up on Open Items A.

The following items are considered closed:

Open Item 88-02-02.

This item concerned formal agreements with the '

-City of San Diego Department of Emergency Services and San Diego County Disaster Preparedness.

The inspector determined that the responses of these two agencies during an emergency is defined by state law; therefore a contract agreement with the licensee is not required.

Open Item 88-02-05.

This item concerned the licensee's failure to conduct required emergency preparedness training.

The licensee's corrective action was to make Emergency Response Recovery Directors (ERRD) directly responsible for the training of their employees.

The inspector reviewed selected training records and found that all required training was current.

This indicates that the corrective action was effective.

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2 Open Item 88-05-05.

This. item involved a review of the results of the licensee's resurvey of the area that previously housed the TRIGA Fuel. Fabrication operation.

The results of the survey indicated the contamination present was at a marginal level relative to the NRC release limits.

The licensee cleaned the largest area to less than the NRC release limits.

The survey report was submitted to the NRC to facilitate its review and the scheduling of an independent 3

overcheck to qualify the area for consideration for release to unrestricted use.

The licensee's plan for the orderly cleanup of the two smaller' remaining E Building areas and thuir subsequent scheduled submittal for independent NRC overcheck warrants closing this item.

The licensee's list of areas that are still candidates for cleanup will continue to be reviewed.

Open Item 88-09-01.

This item involves a need for improvements in procedures and training regarding the calibration and control of the health physics laboratory measurement equipment.

The inspector l

reviewed the procedure HP-170, implemented in January 1989, which establishes a procedure for laboratory alpha-beta counting system range activity limiting values.

This action adequately addresses the concern.

B.

The following items will remain open pending final resolution:

Open Item 87-01-01.

This item concerned the need for conducting independent reviews of drills and training exercises.

The licensee has included a statement in Section 14.3 of the General Emergency Plan requiring an independent review and evaluation of drills and training; however, the requirement does not exist in the Radiological Contingency Plan (RCP).

This item will remain open per. ding inclusion of the requirement in the RCP.

Open Item 88-05-01.

This item addresses the need for the licensee to determine the initial and the continued presence of the neutron absorber (boron) in the " draft tubes" to be used with the larger load scheduled for use in the coater (see Section 3.C.(1)(C)).

Open Item 88-05-02.

This item involves the review of the licensee's procedures developed for operation of the coater with the increased batch size (see Section 3.C.(1)(d)).

3.

Functional or Program Areas Inspected A.

Management Organization and Controls (88005)

This area was examined to assure that the licensee's organization has defined responsibilities and functions, established and implemented the use of approved procedures, performs internal reviews and audits, established a safety review committee, and follows a quality assurance program for equipment and systems important to safety.

(1) Organizational Structure

3 The licensee's organizational structure remains unchanged since the last inspection (Report No. 70-734/88-09).

Changes in responsibilities have been noted in the Hot Cell Area where there is a new principal -investigator, and in the TRIGA Reactors Facility where there is a new Physicist-in-Charge.

4 The position functions are largely the same.

The chairmanship of.the Criticality and Radiation Safety Committee (CRSC)-

remains unchanged.

-(2) Procedure Controls j

The licensee continues to use approved procedures. The j

licensee's practices in following one procedure, FMP-4 " Gas Meter Calibration", indicated a need for closer management oversight in implementation of the procedure (see Section E.).

(3) Internal Review and Audit The licensee has conducted the required nuclear criticality safety inspections (at least annually for all areas and quarterly for areas containing more than 500 gm fissile SNM).

f Additionally, the Health Physics Technicians (HPT) in each area j

have continued to observe criticality and radiation safety practices daily.

Deficiencies identified are reported expeditiously to obtain timely corrective action.

(4) Safety Committee The licensee's Criticality and Radiation Safety Committee (CRSC) continues to meet to provide oversight of safety related 1

programs and conducts annual audits as required.

The annual audit was only recently completed and the report is currently being written.

The report and the follow-up of the identified items will be reviewed during the next inspection.

(5) Quality Assurance Program The licensee's quality assurance procedure for maintenance of the FSV-1, Serial Number 3, cask was reviewed. The records reflected that the cask was serviced annually as required.

The procedure used was current.

Performance in this program area appears to warrant improvement.

l Specifically, additional management oversight on the implementation of L

the procedure used for calibration of the gas meters is needed. The gas meters are an integral part of a safety system.

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4 B.

Operator Training (Module 88010) 1 This area was examined to determine whether the licensee is complying with regulations and license requirements related to the training of licensee employees and other personnel.

The inspector noted that the licensee had conducted 15 Radiation Safety classes to train 153 of its employees during 1988.

From a review of the lesson plan and examination questions the inspector concluded that the training met the requirements stated in the license.

The licensee's records indicated that all Radiological

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training was current.

The inspector interviewed four employees involved in a recent event-regarding a possible loss of radiological material.

The inspector concluded that the employees' training was adequate.

The licensee's performance.in this program area.is consistent with NRC regulations and the' provisions'of the license.

C.

Criticality Safety (88015)

This area was examined to assure that the licensee is using appropriate expertise in establishing criticality safety limits for operations, exercises positive management control to assure i

operations are conducted within criticality safety limits, and the i

licensee's. activities are conducted safely, avoiding the possibility of a criticality accident.

(1) Nuclear Criticality Safety Analysis

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(a) No new Nuclear Safety Analysis (NSA) was required by operations currently being planned.

The operation covered by the last NSA, coating a larger size batch of particles for the Modular HTGR (commercial), has been delayed from a j

planned first quarter startup to a third quarter startup.

(b) The " draft tubes" for the coater modification are a

currently being fabricated.

The " draft tubes" containing i

the neutron absorber (boron) will be engraved with serial i

numbers as well as drawing numbers.

(c) The procedure for verifying the initial boron content and verification of the continued presence of the boron l

throughout the use of the " draft tubes" is still being j

developed.

J (d) The licensee is still developing the procedure for-operation of the coater with the poisoned (boron neutron i

absorber) " draft tube" and the larger oatch size.

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l (e) The Manager of Nuclear Safety required moving containers of SNM to another eisle in the west vault prior to stcrage of the 6M drums in the first aisle because the specific l

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storage configuration of.SNM containers and 6M drums had not been analyzed.

The space in the vault facilitated the

.j change, thus eliminating the need for the analysis.

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container relocation appeared to be an adeouate solution l

to the problem.

1 (f) The inspector noted that'there appears to'be a problem

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developing where the critica14cy reviewer of Radiation Work Permits (RWP) or Work Authorizations (WA) is placing I

conditions on the permit :,r authorization and not j

confirming the implementation of the conditions.

The reviewer signs the RWP or WA with the conditions written on it.

This practice gives up'the element of control that i

assures that the condition will be met-before the permit or authorization is implemented.

It appears that an i

assumption is made that someone else' will check on.it.

This issue is identified as Open-Item 89-01-01.

(2) Audits l

(a) The inspector examined the licensee's criticality safety inspections reports.

The areas inspected by the licensee included the main SNM vault in the SV-A Building', the SV-A l

Fuel Fabrication Facility, and the Triga Fuel Fabrication-Facility.

The. areas were inspected at the required.

frequency (annually for all areas and quarterly for areas containing more than 500 gm of fissile-SNM)..The L

inspections were of sufficient scope and depth. The corrective actions on previous findings were. reported.

(b) The licensee's Nuclear Safety monthly report.' identified l

the use of a posted D-2 station for a small project that had not been included on the applicable WA.. The HPT for the area notified the Nuclear Safety Manager'who immediately called the Production Department Supervisor.

The project had been completed, but a commitment was-obttined to modify the WA to include all stations. to be used if the prcject resumed.

(c) The Nuclear Safety monthly report fnr December,-1988 identified that, if the SV-A Fuel Fabrication' Facility should be authorized to process large quantities of U-235, the ~ inactive station limit signs should be. modified (removed or covered) to preclude a misunderstanding-re w'S ng their applicability.

The licensea foresaw no i

pro,lem i.' this solution and the management of SV-A was requested to include compliance with this. modification when p anning my large-scale SNM activity.-

l (3). Criticality Mon;'oring System (a) The licensee plans to upgrade the criticality alarm system in the Triga Fuel Fabrication Facility.

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-i selected'is similar to the system used in'the main vault 1

and will be installed before the'end of March 1989.

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As the licensee begins to restart operations!in a recently inactive-a area, performance in this program area will warrant close attention in that reactivated area.

Additionally, the criticality safety

.related open-items must be closely followed. No violations were identified.

'D.

Op'erations Review (88020)

This area was inspecte'd to ensure that the licensee is conducting-

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operations safely in accordance with the regulations, the license, the Safety Analysis Report:and applicable regulatory guides, and -

other codes and standards.

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j (1) Hot Cells.

I The inspectors examined the status of.the hot cell operations.

This' operation was previously oriented'towards

-Decontamination / Decommissioning (D/D).. Current efforts. involve

tritium gas extractions. lThe D/D activities are near a 1

standstill pending completion of the tritium extraction project.

Some personnel from other fuel handling' operations-q (SV-A):are receiving some hot cell manipulator training that j

will be.useful when cell D/D resumes.

The HPT pointed out that the hot cell;now had new combination locks.to preclude visitors from walking'into the facility.

unannounced. Additionally, the' inspector noted that the hot-cell and the TRIGA rear yards had been separated by a new fence as the licer,see committed to during the previous inspection.

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(2) TRIGA Fuel Fabrication (TFF) 1 I

The operations.,in this facility were continuing at the low level previously observed..There was.not much to observe currently in that, activities centered around hydriding fuel meats in the hydriding furnace.

The inspector checked the facility fo'r' the presence of an. air flow pump and meter whoseL calibration: records indicated unacceptable airflow performance.

The 'rocords also indicated the unit was supposedly in use,in 1this facility; however,the inspector found that the unit was I not at this facility.

The licensee reported by telenhone on.

1 March 9,:1989, that the unit was not in operation, bc :was l

-located:in the repa'ir' shop'.

The licensee also reported that:a complete survey of.the location of these units was made and the information was' used to update the current-location records.

The manager of the facility indicated that he expected'the installation ct a oes cr Rkality alarm system within a week or so.

.The calibration and performance of this system has been i

identified for review in the. next' inspection.

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c (3) Sorrento Valley A Building (SV-A) i The inspector attended a licensee. planning'm'eting where a e

repacking. operation was discussed.

The procedure for'the-operation:had beer.: prepared,and was reviewed..The meeting attendees includad the operators, their supervisors and quality.'

control'and quality assurance representatives, as well as three>

consultants of...he absent owner of the SNM who were retained to' assure that the operation was properly planned and executed.

The meeting was fruitful 'in that several pertinent suggestions were developed and a dry run suggestion-was scheduled. for implementation within two days because the 'startup of the'

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project'was imminent.

Additionally, the licensee plans an enrichment. blending (downgrading): operation that will include the'use of both this' facility.and SV-B.

The measurement of the portions to be

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blended will occur in SV-A and the blending of the portions will occur in SV-B.. The project is' expected to' overlap'the repackaging operation mentioned above.

(4)-- Sorrento Valley B Building (SV-B) i This facility will be used for the blending portion of the enrichment downgrading project that will be1 starting soon in SV-A. 'The downgrading is being undertaken to preclude the need to meat the facility upgrade requirements soon to be implemented.

The operations in'SV-B do not currently involve. processing 1

Special Nuclear Material (SNM).

The licensee anticipates i'

making a few coater runs with normal or depleted. uranium.

particles to check the coating parameters-for the largen batch size scheduled to be'run at a later date.

(5) Experimental-Building (E-Building)

The licensee submitted the completed survey report to the NRC's Region V office for this and some additional areas in-L-Building that were cleaned to less than NRC release limits.,

The Oak Ridge Associated Universities' (0RAU) is scheduled to do an independent overcheck of the area in.. late March 1989.

Within the ' hot suite' of E-Building only two small areas will remain to be done after. completion of this phase of the i

cleanup.

The licensee is keeping track of all such areas that

-l still need cleanup and an NRC overcheck prior to' release;to unrestricted use.

Performance in this. program area appears adequate.

No violations 0

were identified.

4,

E.

Maintenance and Surveillance Testing (88025)

8 This area was examined to determine.that general maintena'nce op'erations, surveillance tests and calibrations are being. conducted in accordance with license requirements and approved procedures.

Specifically, the calibration of the licensee's air sampling system flow meters (gas meters).was selected for examination during this inspection.

4 (1) The inspector found that the licensee needed to provide additional oversight for.this calibration.

The review of the

~10 most recent calibration' rec'ords identified an incomplete form which also contained a calculation error (a difference was taken instead of'a required ratio). This need for a review of the test results by.someone other than the person performing the ' test is jdentified as Open Item 89-01-02.

(2)-[The. records for two of the flow meters which did not meet the

. calibration. acceptance criteria for airflow (0.9-1.1 correction factor), 'did not reflect that they'were removed from' service.

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l Th'e. inspectors'Jsearch of the record indicated location found

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that the related meter was-not in that service' location.

No location was specified in the record for the second meter.

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licensee continued the search and found the two meters were in

the repair shop. The need to update-the records on the: location.

of the meters and.to tag or otherwise identify meters that do not meet the calibration procedure acceptance criteria is identified as Open Item 89-01-03.

(3) At the time of the: inspection the licensee was not able to locate the data on which the meter calibration frequency was based.

The inspector noted that the licensee cleaned the meters before testing them against the standard and did not

'I record the "as found" meter flowrate.

Recording the "as found" meter flowrate would permit evaluating the performance of the meter at the end of the calibration period and would facilitate evaluating the need to adjust the total flow.

The licensee's data supporting the meter calibration frequency will be 1

reviewed as Open Item 89-01-04.

The licensee's performance in.this program area needs improvement.

L No violations were' identified but several areas warranting additional attention were identified as open items.

Broadening the licensee's internal audits to include these and related items would be beneficial.

F.

Rad'ioactive Waste Management (88035)

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.This area was examined to determine if the licensee was in compliance with the regulations and license. requirements related to-the' release and disposal of liquid and airborne.(gaseous and particulate) waste, and the reporting of effluent-release information to the NAC.

The licensee's effluent reports were issued as required by 10 CFR Part 70.59.

The reports indicated the licensee's effluents (liquid, gas and particulate) were less than

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'l regulatory libiits.. The reports were. issued and submitted to the NRC within the regulatory time requirement.

1" Performance.in this program area appears adequate.

No. violations.'

i were identified.

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G.

Transportation of Radioactive Materials'(86740)~

I This, area was inspected to. determine that the licensee'had established and maintai.ned an adequate management-controlled program' 4

jl to assure radiological and nuclear safety in.the receipt, packaging : delivery to a carrier and, as applicable,. the private

'I carriage-of. licensed radioactive materials; and to determine whether-such transportation activities are in compliance with the applicable NRC and DOT transport regulations.

'.g (1) Hanagement Controls.

(a) Responsibility for transpectation'has been assigned.

(b) The authorities and responsibilities are clearly o

delineated.

(c) Management approved proceduresLare used to assure the shipments are properly prepared.

(2) Introduction and Training Program.

1 The licensee has continued periodically to. send those involved with shipment activities to the transportation classes-that are provided by DOT.

(3) ' Quality Assurance Program.

u The licensee maintains and implements a quality assurance (QA) program.

(a) The QA program for.the FSV-1, Serial No.-3, cask owned by-the licensee was reviewed and appeared adequate.

The procedure used was reviewed and. approved.by appropriate-management.

(b) The records of implementation of the QA program were also reviewed.

The records indicated that the.QA program had I

been followed and appropriately documented.'

(4)' Preparation of Packagings for Shipment.

The licensee has in place an approved procedure NMA-4 " Shipment of Radioactive Mate' rial" for preparation of packages for.

s shipment.

The procedure, issue E, was last. updated in March, l

1988.

The inspector's' review of the procedureLnoted it contained appropriate checklists that with proper use should

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m 10 assure that the licensee's shipments will be in compliance with the regulations'.

(5) : Periodic Maintenance of Packagings.

The licensee maintains a current record of the packagings that he uses.

Additionally, the licensee is responsive to notifications about containers.

Recently, the licensee received notification from the Department of Energy'(DOE)-that type 6M shipping containers needed to be inspected for flaws.

An inspection program was setup and all of the 6M containers'he recently acquired were inspected.

The licensees' response to the notification ~ appeared appropriate.

The licensee was cited by the state of Washington for use of-the trailer doors as bracing on a recent shipment.

This was -

1 identified as an open item (number 88-09-02) during the.last

'j inspection.

The licensee has modified the loading charts:for i

all such trailers to' assure sufficient room would be left behind the last items loa,ded to permit the installation of proper bracing before the doors of the trailer are closed.

This' action adequately precludes repetition of the error.

This item is closed.

Performance in this program area appears adequate.

No violations were identified.

H.

Radiation ' Protection (Module 83822)

I This area was inspected to determine whether:the licensee is complying with-regulatory requirements related to radiation protection, and to evaluate the adequacy of~certain aspects of the licensee's radiation protection program.

The inspectar reviewed the licensee's external and internal exposure control programs.

No significant' changes since the last inspection (report number 70-734/88-09),were noted.

There had been no occa-sions where the exposure limits of 10 CFR 20.101(a) were exceeded.

Portable survey instruments were,all operable and calibrated in accordance with procedures.

The licensee's program appeared consistent w..h ALARA principles.

During the past year, in addition to the ongoing ALARA program, the licensee had accomplished the removal of two hot cell tanks which-were contributing 200-800 mr/hr t, the general area.

Also, waste barrels in the hot cell storage yard had been removed, reducing radiation levels in that general area to about 1.5 mr/hr.

The radiological control procedures and equipment ~had not been significantly changed since the last inspection.

Records of air samplings, radiological surveys, and radiological work permits were reviewed.

All were found to be appropriate and performed in accordance with procedures.

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1 The inspectorfreviewed a document, Internal Correspondence (No.

LRQ: 88:142), dated December 1, 1988, addressed to General Atomics' principal investigators.

The correspondence was.. initiated in response.to an_NRC observation.that corrective actions to internally-identified items were not being conducted in a timely manner.. The correspondence requested immediate corrective action on, any' pending. internally-identified items.

Responses to.the above correspondence' indicated that all items have been' addressed and almost all:had been completed.

Satisfactory progress had been made'

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on the remaining items.

A random sampling of NRC Form 4 exposure recor's were examined for;

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d completeness and accuracy.

Exposure totals ~on one' record were found 1

'to be incorrect and one record contained undocumented pen-and-inki changes to-the' exposure.

This indicates a possible inability to

. maintain accurate and complete exposure history records.

The.

licensen's' response to this weakness will be reviewed in a subsequent-inspection and' will be tracked as Open : Item 89-01-05.

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Emergency Preparedness (Module 88050)

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This area was i'nspected to, assure that the' licensee's emergency.

preparedness program is adequate to maintainLemergency readiness, that plantJpersonnel are adequately trained in emergency procedures, that the licensee is conducting drills and tests as specified in the facility emergency plan, Land that.the licensee is coordinating with.

offsite, support agencies as specified.in the emergency plan; While there have been no significant staff and organization changes in the emergency response program since the last inspection, the-licensee has made significant changes to the' Radiological Contingency Plan (RCP).

The revision was-implemented in late-December 1988.

The GA license provides-for such changes to be.made without prior N@C approval and allows six months to report the changes to the.MRC.

Because some of the GA property was soldif the site. boundary had to be redefined.

The inspector toured the-revised site boundary and.

noted that appropriate relocation of environmental monitoring equipment had been made as necessary. ' All emergency kits examined were found to contain the correct inventory and equipment was operable and withirt current calibration dates.

1 The inspector noted that the licensee had not exercised the full..

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implementation of its RCP..Untillan integrated' drill,is conducted to exercise all components of the emergency response organization, the effectiveness of the RCP cannot be determined.

This. failure to-demonstrate the response capability of'the RCP is a concern of.

3 safety significance.

The licensec's response to this ; concern will:

be evaluated during a future inspection.

This item will be. tracked as Open Item 89-01-06.

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m 12' Exceptifor'the failure to conduct an exercise. involving all, parts of the' emergency response. organization, performance in this' program area was acceptable.

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Environmental Protection (Module 88045)'

This;programaNeawasinspectedto;ensurethat.thelicenseeis-y implementing-license commitmentsifor the environmental program'and-i maintaining adequate management. controls to provide reasonable l

assurance that the' impact on the environment and the publiceis

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minimal.

Since the last inspection the. licensee has reduced.the-number of. environmental monitoring' stations from 21 toL16 because ofc I

I a change'in the usage of some facilities..This reduction was reflected in Revision 12 (4/88)~of the General Atomics. license as-required.

There were no other significant changes.in this program area.

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The licensee's performance in this area is consistent with Federal-l regulations and the provisions of.the license.

K.

Exit Meeting (30703)

The'results of the inspection'were discussed with the'lJcensee's staff identified in Section 1.

The topics covered included:.a review; of the' findings ~in each area inspected and~the status of the open-

'l items covered.

The following items were specifically addressed.

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The licensee should improve management' oversight of tiw %ir -

sampling program.

Attention should be directed towards form completion, calculation accuracy, control of equipment no?

meeting the calibration air flow specifications, recording'"as found" data, and accumulating data supporting the calibration frequency.

o Importance of " Draft Tube" identification using serial numbers and drawing numbers.

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' Progress in planning the verification of the initidicand continued presence of the boron neutron absorber.

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o Open items status:

- closed 4, h

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- 3 remain open k,

- opened 6 j

The inspector noted th'at the licensee has yet to conduct a f 1 o

-scale exercise of its RCP.

This. failure to demonstrate the'

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response.of the Radiological Contingency Plan is a concern of safety significance that will be considered during license renewal l

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