ML003767866
| ML003767866 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 10/10/2000 |
| From: | Asmussen K General Atomics |
| To: | Adams M, Rogus R NRC/NMSS/FCSS, State of CA, Dept of Health Services |
| References | |
| -RFPFR, CAL/696-3285 | |
| Download: ML003767866 (8) | |
Text
+ GENERAL ATOMICS October 10, 2000 CALU696-3285 ATTN: Dr. Ron Rogus (in Duplicate)
State of California Department of Health Services Radiologic Health Branch, Mail Stop 178 601 North 7th Street Sacramento, CA 95814-0208
Subject:
Radioactive Materials License No. 0145-37: Request for Release of Outside Areas Adjacent to Building 27 on the East and Northeast and Ms. Mary Adams, Mail Stop TWFN 8 A-33 Fuel Cycle Licensing Branch Division of Fuel Cycle Safety And Safeguards, NMSS U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Docket No.70-734; SNM-696: Request for Release of Outside Areas Adjacent to Building 27 on the East and Northeast
Dear Dr. Rogus and Ms. Adams:
In November 1999, General Atomics (GA) completed final radiological surveys and measurements demonstrating that the small land areas surrounding its Building 27 meet the criteria for release to unrestricted use. The location and boundary of the outside land areas associated with Building 27 are shown on the attached Figure 1 (Figure 3 of Ref.1). By letter dated November 23, 1999, GA requested the State of California DOHS Radiologic Health Branch (State) to conduct confirmatory surveys of this outside area (Ref. 2). The State responded by scheduling a confirmatory survey visit for December 2-3, 1999.
In support of GA's request for a confirmatory survey and the release of the Building 27 land areas to unrestricted use, GA documented the results of its final radiological surveys in a report titled "Final Radiological Survey Performed at General Atomics' Open Land Area Associated with Building 27," dated November 30, 1999 (Ref. 1). Subsequent to the preparation of this final report, but prior to requesting the release of the Building 27 land areas, and as will be explained below, only a portion of the surveyed land area was accessi ble for confirmatory surveys on December 2-3, 1999. The then-accessible portion of the Building 27 land area was comprised of three areas, i.e., the areas to the west, south and southeast of Building 27 as shown on the attached Figure 2.
Because it was important for GA to obtain the timely release of the three then accessible areas around Building 27, GA's release request dated December 2, 1999 (Ref.
3), was limited to only the west, south, and southeast land areas as shown on the attached 3550 GENERAL ATOMICS COURT, SAN DIEGO, CA 92121-1194 PO BOX 85608, SAN DIEGO, CA 92186-5608 (619) 455-3000 w/s
Dr. Ron Rogus, DOHS / Ms. Mary Adams, NRC CALU696-3285 October 10, 2000 Page 2 Figure 2. This release request was submitted to the State, with a copy to the U.S. Nuclear Regulatory Commission (NRC). It requested the release of the land areas adjacent to GA's Building 27 on the west, south and southeast plus materials removed from those areas (e.g.
soil, concrete and asphalt) to unrestricted use and their deletion from GA's State and NRC licenses.
Subsequently, the outside areas to the west, south, and southeast of Building 27, plus debris removed from land associated with Building 27, were released to unrestricted use by the State (Ref. 4) and the NRC (Ref. (5).
GA's final survey report submitted by Reference 3, documented the results of GA's final radiological surveys demonstrating that the land areas to the east and northeast of Building 27 meet the criteria for release to unrestricted use. In February and March of 2000, the State conducted confirmatory surveys and measurements which verified that these land areas meet the criteria for release to unrestricted use. Accordingly, GA, now, requests that the land areas to the east and northeast of Building 27, as shown on the attached Figure 3, be released to unrestricted use. The total area is _ 55 m2 (~-592 ft2).
Background
After GA prepared its final report documenting the results of its final radiological surveys and measurements on the land areas surrounding Building 27, but prior to the State's confirmatory survey visit, it became necessary to: 1) conduct additional radiological measurements and submit an addendum to the initial final survey report, and 2) limit the scope of the initial release request to only a portion of the land area addressed in the final survey report (Ref. 1). The circumstances associated with each of these is summarized below:
First, in preparation for reoccupying the released and refurbished Building 27, it was necessary to remove and replace the asphalt parking areas located on the south and south east land areas (see attached Fig. 2). This involved removal of the asphalt and the top 1' of soil beneath the asphalt. The asphalt and soil were removed and stored in locations T-1 8, T-23, T-36 and T-37 in GA's Soil Staging Area (SSA) pending their release to unrestricted use. Upon notifying the State of this activity, the State requested GA to conduct surveys on the newly exposed soil surfaces (before repaving) and to submit a report providing the results of these surveys. These surveys were completed, the results were documented in draft form, and this information was provided to Ms. Lisa Brown (State) prior to her scheduled confirmatory survey visit of December 2-3, 1999.
An addendum to the initial final survey report (Ref. 1) was formally submitted to the State and NRC by letter dated January 26, 2000 (Ref. 6). The data in this report titled, "Addendum # 1 to the Final Radiological Survey Performed at General Atomics' Open Land Area Located to the West, South and Southeast of Building 27," demonstrated that the newly exposed land areas located to the south and southeast of Building 27 meet the approved criteria for release to unrestricted use. In addition to documenting the results of
Dr. Ron Rogus, DOHS / Ms. Mary Adams, NRC CAU696-3285 October 10, 2000 Page 3 GA's radiological surveys on the newly exposed surfaces, the addendum report showed the locations where Ms. Lisa Brown (State) collected soil samples and provided the results of GA's gamma spectroscopy analysis of those samples which were split with GA.
The second circumstance involved the land areas to the east and northeast of Building 27 (see attached Fig. 3). The results of GA's final surveys for these areas were documented in the final survey report (Ref. 1) submitted with GA's initial request for release (Ref. 3). Unfortunately, subsequent to GA's initial request, but prior to the State confirma tory survey visit, portions of these land areas were covered with concrete newly poured in support of refurbishment around Building 27. This resulted in a portion of the land area included in GA's initial request being inadvertently inaccessible during the State's scheduled confirmatory visit of December 2-3, 1999.
Pursuant to discussions with the State, it was agreed that the scope of Ms. Brown's confirmatory survey visit of December 2-3, 1999 would be limited to those portions of the subject land area near Building 27 that were accessible on December 2, 1999. These accessible areas were to the west, south and southeast of Building 27 (see attached Fig. 2).
It was further agreed that the land areas to the northeast and to the east of Building 27 (see attached Fig. 3) would be addressed separately at a later date (which is the purpose of this letter.)
During Ms. Brown's survey of the accessible areas near Building 27 on December 2 3, 1999, she collected several soil samples (including samples from the material (e.g., soil and asphalt) stored at the SSA), some of which were split with GA. GA's analyses of these samples showed radionuclide concentrations at or near background levels and well below the approved release criteria.
By letter of January 4, 2000, the State (Dr. Ron Rogus) requested that GA remove the recently poured section of concrete between Buildings 21 and 27 to make it possible to perform a confirmatory survey of the area. This area was within the "east" area (see attached Fig. 3). Concrete was removed on February 17, 2000 in an area of about 32.4 m2 (after discussions and approval by the State). Drawings and pictures of this area were mailed to Ms. Lisa Brown (State) on February 17, 2000. Ms. Brown then visited GA on Friday, March 3, 2000 to perform confirmatory survey measurements on this area. In addition, she collected more soil samples from the debris (asphalt and soil) stored at the SSA area that originally came from around Building 27. Ms. Brown returned to GA on March 30, 2000 to complete the survey within the "east area."
The above mentioned debris (asphalt, soil and concrete from the surface of the Building 27 outside areas) is temporarily being stored in bins T-1 8, T-23, T-36 and T-37 at the SSA. Radiologic measurements/surveys demonstrating that this debris (e.g., soil, concrete, and asphalt) from around Building 27 meets the criteria for release to unrestricted use was documented in the radiological survey report provided in Reference 3. Additionally, Ms. Lisa Brown collected samples from, and radiologically surveyed, this debris to confirm that it meets the criteria for release.
Dr. Ron Rogus, DOHS / Ms. Mary Adams, NRC CALU696-3285 October 10, 2000 Page 4 GA has received State License Amendment No. 142 (Ref. 5) and NRC License Amendment 67 (Ref. 6) in response to GA's requests described in References 3 and 4. GA understands that these license amendments release the land areas to the west, south, and southeast of Building 27 plus debris/materials (e.g., soil, concrete and asphalt) removed from the land areas associated with Building 27.
Request for Release The final radiological survey report (Ref. 1) submitted by Reference 3 documented the results of GA's radiologic surveys and measurements for the land areas to the east and northeast of Building 27 as shown on the attached Figure 3. The referenced survey infor mation demonstrates that the Building 27 east and northeast land areas meet the State and NRC-approved criteria for release to unrestricted use. Because these areas were not included in GA's initial release request (Ref. 3), and because these same areas have now been the subject of confirmatory measurements by the State which verified that they meet the criteria for release, GA now requests the State and NRC to release the Building 27 east and northeast land areas, as shown on the attached Figure 3, to unrestricted use and delete them from GA's State and NRC Licenses 0145-37 and SNM-696, respectively. The total area to be released to unrestricted use is -55 m2 (-592 ft2).
If you should have any questions regarding the information provided, please contact Mr. Paul R. Maschka at (858) 455-2959, Ms. Laura Q. Gonzales at (858) 455-2758, or me at (858) 455-2823. Your assistance in responding to our request is very much appreciated.
Very truly yours, Keith E. Asmussen, Ph.D., Director Licensing, Safety and Nuclear Compliance Figure 1: Building 27 Outside Land Area Figure 2: Building 27 West, South, and Southeast Land Areas Figure 3: Building 27 East and Northeast Land Areas cc:
Mr. Wayne L. Britz, Fuel Cycle Inspector, NRC Region IV Ms. Kathleen Henner, State of California, DOHS, Brea, CA
Dr. Ron Rogus, DOHS / Ms. Mary Adams, NRC CAIU696-3285 October 10, 2000 Page 5
References:
(1)
"Final Radiological Survey Performed at General Atomics' Open Land Area Associated with Building 27," General Atomics report dated November 30, 1999.
(Submitted to the State of California and NRC by Reference 3.)
(2)
Asmussen, Keith E. Letter No. CAL-3155 to Dr. Ron Rogus, "Request for Confirm atory Survey of Outside Area Around Building 27 and the EA-1 Bunker Pit," dated November 23, 1999.
(3)
Asmussen, Keith E. Letter No. CALU696-3159 to Dr. Ron Rogus with copy to Charles Gaskin, "Request for Release of Portions of the Land Area Near and Adjacent to General Atomic's Building 27 to Unrestricted Use and its Deletion from GA's License," dated December 2, 1999.
(4)
State of California Radioactive Materials License No. 0145-37; Amendment No. 142 dated June 27, 2000.
(5)
U.S. Nuclear Regulatory Commission Special Nuclear Material License SNM-696; Amendment No. 67 dated September 18, 2000.
(6)
Asmussen, Keith E. Letter No. CALU696-3179 to Mr. Dave Wesley and Ms. Mary Adams, Addendum Report in Support of GA's Request for Release of Portions of the Land Area Near and Adjacent to GA's Building 27 to Unrestricted Use and Its Deletion from GA's License: "Building 27 West, South and Southeast Land Areas,"
dated January 26, 2000.
Dr. Ron Rogus, DOHS / Ms. Mary Adams, NRC October 10, 2000 Figure 1: Building 27 Outside Land Areas 28 CAL/696-3285 Page 6 N
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Dr. Ron Rogus, DOHS / Ms. Mary Adams, NRC October 10, 2000 Figure 2: Building 27 West, South and Southeast Land A I I....
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Dr. Ron Rogus, DOHS / Ms. Mary Adams, NRC October 10, 2000 Figure 3: Building 27 Northeast and East Area Land Areas Sidewalk BUILDING 27 CAL/696-3285 Page 8 21 BUILDING 21 N
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