ML103430567

License Requirement for Facilities Repairing Contaminated Equipment

ML103430567
Person / Time
Issue date:	12/13/1977
From:	Fisher W NRC/RGN-III
To:
References
05484-309
Download: ML103430567 (9)

Text

132 RECORD #132 TITLE: License Requirement for Facilities Repairing Contaminated Equipment FICHE: 05484-309 3,

132

• r UNtTED STATES NUCLEAR REGULAIORY COMMISSION REGION III 799 ROOSEVELT ROAD GLCN. ELLYN, ILLINOIS 60137 December 13,' 1977 NEMORANDUM FOR: Inspection Staff FROM: W. L. Fisher, Acting Chief, Fuel Facility and Materials Safety Branch

SUBJECT:

OFFSITE REPAIR OF CONTAMINATED ITEMS EMVIORA NDUM NO. M 14 The attached letter contains guidance for a rather common problem. Please bring this to the attention of all reactor, fuel cycle, and other licensees who might find themselves in need of sending a contaminated item to an unlicensed facility.

W. L. Fisher, Acting Chief Fuel Facility and Materials Safety Branch

Attachment:

Ltr dtd 11-1-77

W.ill IPSIATES W NUCLEAR R13(;U1LAI OR Y COMM~ISSION '

WAStimci I ON. D. C. 20555 V Novem~ber 1, 197 A

V.

V TO ALL PO*ER REACTOR FIX II,ITY, LCF1:$ErS Gentlemen: V It has come to our attention tlat tC reactor Jacility licensees ýJl occasionally find it necessay to s nd a comporent contaminated with "1 radioactivity to rmanufacturers or se 'vice companies for repair or calibration. 1t is not alhays pract cal or feasible, however, for the facility licenseetob 'reduce the r dioactivity associated with thQ component to le%,;el.s acceptable fo unrestricted use. The manufacturers or service colapanies do not, in many cases, have appro._i*atC 'IC or Agreei:ient State .licenses authorizing- receipt, po,->ession, use and transfer of byproduct material nor do they have

-the qualified personnel necessary to obtain such licenses. The ship-ment of these components by or to unlicensed persons has resulted in enforcement action being taken, against-the'persons shipping or receiving

.the conta:minated ccwponents. Urgently needed repairs and service have been delayed while the concerned regulatory agencies attempted to resolve the problem.

It is essential that appropriate licenses be held by the repair shop or the facility licensee in accordance with the guidance of this letter, prior to shipment of the contaminated component. Some .RC facility licensees have obtained I.RC or Agreement State licenses,.as appropriate, authorizing possession and use of components containing byproduct material at uý,'pecified, off site locations throughout the state in which the facility is located. We suggest that you consider obtaining such a license to avoid such problems.

Applications to the MRC or to an Agreement State by NRC facility.

licensees for such byproduct materials licenses must be completely supported by necessary information, including contract provisions to be

,eimplo.l'ed to deoonstrete fuill licensee control of all related matters, Ssuch. as shipping procedures, health physics-support personnel, health

.physics procedures- traiuing and experience, cleanup op.erations, and,-'

-fi-nal survey..reports.Y- In instances where full .licensee contrpl- o.f all matters relating to t he contar'iinated. item, while in the'repaiir shop is rot intended or is.-not feasible, the repair shop must obtain the appropriate license to per;,it the repair. If the licensee is able to satisfy the requirefments for a byproduct materials license authorizing possession and.use of his conta:;ir*ated rr.aterials at unspecified sites, he may, in accordancc with reciprocal .RC or Agreement State regulations receive, possess, use and trarnsfer such contaiiinated components at unspecified off-site locations- in other states.

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If the facility is located in a non-Agreement State, the NRC byproduct material license (issued pursuant to 10 CFR Part 30) would authorize the possession and use of the contaminated component in other non-Agreement States. ly notifying the appropriate Agreement State authority by letter, or if necessary by telephone, at least five days prior to shipment of a contaminated cc:,pLnent, an I4RC licensee authorized to possess end use components containing byproduct material at unspecified off site locations throughout a non-Agreement State can (pursuant to Agreement State regulations similar to 10 CFR 150.20) obtain authorization

-to conduct the same activities within an Agreeý,ient State.

If the licensed facility is located in an Agreement State, the facility licensee must obtain from the Anreement State a license authorizinci.

possession and use of components containing byproduct naterial at unspecified locations throunlhout that State. Under the reciprocity provisions. Of 10 CFP 150.20 and similar provisions in other Agreement State regUlations, the licensee is permitted (for up to 180 days in any calendar year) to c-onduct the same activities in othcr Acreement and non-Aareement- StAtes. If the shipment is to be made to a location in a non-agrecment State, NRC Form 241 must be submitted at least three days prior to shipment. A copy of Form 241 is enclosed with this letter (enclosurel). For shipments to locations in other Agreenient States, appropriate notification toust be marie. If the licensee-conducts the same activity for more than lIN days in any calendar year in any othler state 1.h.-.n the one for which the license was issued, he mnust o'.tain another byproduct material license from the NRC or the Agreement State, as appropriate, authorizing him to conduct such activities in that State.

For facilities locat.ed in a non-Agreement State, an' application forn and guidance for these 1,-.prodtjct materials licenses are included as Enclosurcs 2 and 3. [or facilities located- in Aoreemient States,- you should contact the appropriate A.1reement State licensing official (see-Enclosure 4).

(7,Sincerely, Karl R. Goller, Assistant Director for:Opc-rating Reactcors "

Division of Operating Reactors

Enclosures:

1. NPRC Form 241

2. Application form

3. Guidatice

4. Agrc.!nent States cc w/o enclosures:

See next page

June 1974 U.S. ATOMIC ENERGY COMMISSION 1 1)0 REGULATORY DIRECTORATE OF REGULATORY STANDARDS GUIDE REGULATORY GUIDE 1.86

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V TERMINATION OF OPERATING LICENSES FOR NUCLEAR REACTORS I

A. INTRODUCTION A licensee having a possession-only license must retain, with the Part 50 license, authorization for special Section 50.51, "Duration of license, renewal," of 10 nuclear material (10 CFR Part 70, "Special Nuclear CFR Part 50, "Licensing of Production and Utilization Material"), byproduct material (10 CFR Part 30, "Rules Facilities," requires that each license to operate a of General Applicability to Licensing of Byproduct production and utilization facility be issued for a Material"), and source material (10 CFR Part 40, specified duration. Upon expiration of the specified. "Licensing of Source Material"), until the fuel, radio-period, the license may be. either renewed or terminated achive components, and sources are removed from the by the Commission. Section 50.82, "Applications for facility. Appropriate administrative controls and facility termination of licenses," specifies the requirements that requirements are imposed by the Part 50 license and the must be satisfied to terminate an operating license, technical specifications to assure that proper surveillance including the requirement that the dismantlement of the is performed and that the reactor facility is maintained facility and 'disposal of the component parts not be in a safe condition and not operated.

inimical to the common~defense and security or to the health and safety of the public. This guide describes A possession-only license permits various options and methods and pcedures considered acceptable by the procedures for decommissioning, such as mothballing, Regulatory staff for the termination of operating entombment, or dismantling. The requirements imposed licenses for nuclear reactors. The Advisory Committee depend on the option selected.

on Reactor Safeguards has been consulted concerning this guide and has concurred In the regulatory position. Section 50.82 provides that the licensee may dis-mantle and dispose of the component parts of a nuclear B. DISCUSSION reactor in accordance with existing regulations. For research reactors and critical facilities, this has usually When a licensee decides to terminate his .nuclear meant the disassembly of a reactor and its shipment reactor operating license, he may, as a first step in the offsite, sometimes to another, appropriately licensed process, request that his operating license be amended to organization for further use. The site from which a restrict him to possess but not operate the facility. The reactor has been removed must be decontaminated, as advantage to the licensee of converting to such a necessary, and inspected by the Commission to deter-possession-only license is reduced surveillance require- mine whether unrestricted access can be approved. In ments in that periodic surveillance of equipment im- the case of nuclear power reactors, dismantling has portant to the safety of reactor operation is no longer usually been accomplished by shipping fuel offsite, required. Once this possession-only license is issued, making the reactor inoperable, and disposing of some of reactor operation is not- permitted. Other activities the radioactive components.

related to cessation of operations such as unloading fuel from the reactor and placing it in storage (either onsite Radioactive components may be either shipped off-of offsite) may be continued. site for burial at an authorized burial ground or secured USAEC REGULATORY GUIDES Cop;. of published uides may be obteirnd by request ind;ot, the diisiOno desired to the US. Atomic Energy Commrnion. Washington. D.C. 20645, Regulatory Guideo ama issued to describe end make wvailable to the public Attention: Oirector of Regulatory Sionderds. Commtents and ouvgstions for trathods ac*epuable to the AEC Regulatory satff of implementing sapcific patt of irrprowarments in these ides we encouraged and should be sent t the Secretary the Comcnaeiov's regutatiori, to delineate techniques .,a"db, the staff in of the Commnssion. Ul. Atomic Energy Commission. Wahington. O.C. 20545, evluating apspfic problems or postulated eisgocdnts, or to provide guidance to Attention: Chief, Public Procedings Staff.

epplicnts. Regulatory Guido ar not substitutes for reguilaicons and compliana with themi not reQuired. Metthods and solutions different fromn thaw set out in The guidesae issued in the following ten broad divisions:

the quiclo will be acceptable if they pro-ide a basis for the findings requisite to G__ the vioan or ontimaene of a permit or ficere by the Commission. 1. Power ReactNors 6. Product

2. Research and Test Reactors 7. Trarsportation

3. Fuels end Materia*l Fcilmiis 9. Occuaioaltl Health Publshes guides will, be revised periodimlly; as appropriate. to accommodste 4. Environmental and Siting 9. Antitrust Review comrnism and to reflect rew infornltion or experience. 5. Materials and Plant ProtectiO*n 10. Gerafl

I on the site. Those radioactive materials remaining on the fluids and waste should be removed from the site.

site must be isolated from the public by physical barriers Adequate radiation monitoring, environmental surveil-or other means to prevent public access to hazardous lance, and appropriate security procedures should be" levels of radiation. Surveillance is necessary to assure the established under a possession-only license to ensure that long teim integrity of the barriers. The amount of the health and safety of the public is not endangered.

surveillance required depends upon (1) the potential Laz3:.d to the health and safety of the public from b. In-Place Entombment. In-place entombment con-i.Ji.-.tive material remaining on the site and (2) the sists of sealing all the remaining highly radioactive or integrity of the physical barriers. Before areas may be contaminated components (e.g., .the pressure vessel and released for unrestricted use, they must, have been reactor 'internals) within a structure integral with the decontaminated or the radioactivity must have decayed biological shield after having all fuel assemblies, radio-to less than presgribed limits (Table I). active fluids and wastes, and certain 'selected com-portents shipped offsite. The structure should provide The hazard associated with the retired facility is integrity over the period of time in which significant evaluated -by considering the amount and type of quantities (greater than Table I levels) of radioactivity remaining contamination, the degree of confinement of remain with the material in the entombment. An the remaining radioactive materials, the physical security appropriate and continuing surveillance program should provided by the confinement, the susceptibility to be established under a possession-only'license.- "

release of radiation as a result of natural phenomena, and the duration of required surveillance.

c. Removal of Radioactive Componeints and Dis-mantling. All fuel assemblies, radioactive fluids. and C. REGULATORY POSITION waste, and other materials having activities above ac-cepted unrestricted activity levels (Table 1) should be I. APPLICATION FOR A LICENSE TO POSSESS BUT removed from the site. The facility owner may then have NOT OPERATE (POSSESSION-ONLY LICENSE) unrestricted use of the site with no requirement for a license: If the facility owner so desires, the remainder of A request to amend an operating license to a the reactor facility may be dismantled and all vestiges possession-only license should be made to the Director removed and disposed of.

of Licensing, U.S. Atomic Energy Commission, Washing-ton, D.C. 2-457. The request should include the d. Conversion to a New Nuclear System or a Fossil following information: Fuel System. This alternative, which applies only to nuclear power plants, utilizes the-existing turbine system

a. A description of the current status of tlw facility. with a new steam supply system. The original nuclear steam supply system should be separated from the.

b. A description of measures that wfll be taken to electric generating system and disposed ofin accordance prevent criticality or reactivity changes and to minimize with one of the previous three retirement alternatives.

releases of radioactivity fiom the facility.

3. SURVEILLANCE, AND SECURITY FOR THE RE-

c. Any proposed changes to the technical specifica- TIREMENT ALTERNATIVES WHOSE FINAL tions that reflect the possession-only facility status and STATUS REQUIRES A POSSESSION-ONLY the necessary disassembly/retirement activities to be LICENSE performed.

A facility which has been licensed under a posses-

d. A safety analysis of both the activities to be sion-only license may contain a significant amount of accomplished and the proposed changes to the technical radioactivity in the form of activated and contaminated specifications. hardware and structural materials. Surveillance and

e. An inventory of activated materials and their commensurate security should be provided to assure that the public health and safety are not endangered.,,

location in the facility.

a. Physical security to prevent inadvertent exposure

2. ALTERNATIVES FOR REACTOR RETIREMENT of personnel should be provided by multiple locked barriers. The presence of these barriers should make it Four alternatives for retirement of nuclear reactor extremely' difficult for an unauthorized person to gain facilities are considered acceptable by the Regulatory access to areas where radiation or contamination levels staff. These are: exceed those specified in Regulatory Position C.4. To prevent inadvertent exposure, radiation areas above 5

a. Mothballing. Mothballing of a nuclear reactor mR/hi, such as near the act'ivated primary system of a facility consists of putting the facility in a state of power plant, should be appropriately marked and should protective storage. In general, the facility may be left not be accessible except by cutting of welded closures or intact except that all fuel assemblies and the radioactive the disassembly and -removal of substantial structures 1.86-2

and/or shielding material. Means such as a remote- (1) Environmental surveys, i' readout intrusion alarm system should be provided to w indicate to designated personnel when a physical barrier (2) Facility radiation surveys, is penetrated. Security personnel that provide access control to the facility may be used instead of the (3) Inspections of the physical barriers, and physical barriers and the intrusion alarm systems..

,(4) Abnormal occurrences.

b. The physical barriers to unauthorized entrance into the facility,' e.g.; fences, buildings, welded doors, and access openings, should be inspected at least 4. DECONTAMINATION FOR RELEASE FOR UN-quarterly to assure that these barriers, have not deterior- RESTRICTED USE ated and that locks and locking apparatus are intact.

If it is desired to terminate a license and to eliminate

c. A facility radiation survey should be performed at any further surveillance requirements, the facility should least quarterly to verify that no radioactive material is be sufficiently decontaminated to prevent risk to the escaping or being transported through the containment public health and safety. After the decontamination is barriers in the facility. Sampling should be done along satisfactorily accomplished and the. site inspected by the most probable path by which radioactive material the Commission, the Commission may authorize the such as that stored in the inner containment regions license to be terminated and the facility, abandoned or could be transported to the outer regions of the facility released for unrestricted use. The licensee should per-and ultimately to the environs. form the decontamination using the following guide-lines:

d. An environmental radiation survey should be performed at least semiannually to verify that no a. The licensee should make a. reasonable, effort to signficant amounts of radiation have been released to the eliminate residual contamination.

environment from the facility. Samples such as soil, vegetation, and water should be taken at locations for b. No covering should be applied to radioactive which statistical data has been established during reactor surfaces of equipment or structures by paint, plating, or operations. other covering material until it is known that contamina-tion levels (determined by a survey and documented) are

e. A site representative should be designated to be below the limits specified in Table I. In addition, a responsible for controlling authorized access into and reasonable effort should be made (and documented) to movement within the facility. further minimize contamination prior to any such covering.

f. Administrative procedures should be established for the notification and reporting of abnormal occur- c. The radioactivity of the interior surfaces of pipes, rences such as (1) the entrance of an unauthorized. drain lines, or ductwork should be determined by person or persons into the facility and (2) a significant making measurements at all traps and other appropriate change in the radiation or contamination levels in the access points, provided contamination at these locations facility or the offsite environment. is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces

g. The following reports should be made: of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or (1) An annual report to the Director of Licensing, location as to make the surface inaccessible for purposes U.S. Atomic Energy Commission, Washington, D.C. of measurement should be assumed to be contaminated 20545, describing the results of the environmental and in excess of the permissable radiation limits.

facility radiation surveys, the status of the facility, and an evaluation of the performance of security and d. Upon request, the Commission may authorize a surveillance measures. licensee to relinquish possession or control of premises, equipment, or scrap having surfaces contaminated in (2) An abnormal occurrence report to the Regula- excess of the limits specified. This may include, but is tory Operations Regional Office by telephone within 24 not limited.to, special circumstances such as the transfer hours of discovery of an abnormal occurrence. The of premises to another licensed organization that will abnormal occurrence will also be reported in the annual continue to work with radioactive -materials. Requests report described in the preceding item. for such authorization should provide:

h. Records or logs relative to the following items (1) Detailed, specific information describing the should be kept and retained until the license is termi- premises, equipment, scrap, and radioactive contami-nated, after which they may be stored with other plant nants and the nature, extent, and degree of residual records: surface contamination.

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(2) A detailed health and safety analysis indi- or a change in the technical specifications should be cating that the residual amounts of materials on surface reviewed and approved in accordance with the require-areas, together with other considerations such as the ments of 10 CFR §50.59.

prospective use of the premises, equipment, or scrap, are unlikely to result in an -unreasonable risk to the health If major structural changes to radioactive components and safety of the public. of the facility are planned, such as removal of the pressure vessel or major components of the primary

e. Prior to release of the premises for unrestricted system, a dismantlement plan including the information use, the lice nsef sho.uld make a comprehensive radiation required by §50.82 should be submitted to the Commis -

survey establishing that contamination is within the sion. A dismantlement plan should be submitted for all limits specified in Table I. A survey report should be the alternatives of Regulatory Position C.2 except filed with the Director of Licensing, U.S. Atomic Energy mothballing. However, minor disassembly activities may Commission, Washington, D.C. 20545, with a copy to still be performed in the absence of such a plan, the Director of the Regulatory Operations Regional provided they are permitted by existing operating and Office having jurisdiction. The report should be filed at maintenance procedures. A dismantlement plan should least 30 days prior to the planned date of abandonment. include the following:

The survey report should:

a. A description of the ultimate status of the facility (1) Identify the premises;

b. A description of the dismantling activities and the (2) Show that reasonable effort has been made to precautions to be taken.

reduce residual contamination to as low as practicable levels; c. A safety analysis of the dismantling activities including any effluents which may be released.

(3) Describe the scope of the survey and the general procedures followed; and d. A safety analysis of the facility in its ultimate status.

(4) State the finding of the survey'in units specified in Table 1. Upon satisfactory review and approval of the dis-mantling plan, a dismantling order is issued by the A After review of the report, the Commission may Commission in accordance with §50.82. When dis-inspect the facilities to confirm the survey prior to mantling is completed -and the Commission has been granting approval for abandonment. notified by letter, the appropriate Regulatory Opera-tions Regional Office inspects the facility and verifies S. REACTOR RETIREMENT PROCEDURES completion in accordance with the dismantlement plan.

If residual radiation levels do not exceed the values in As indicated in Regulatory Position C.2, several Table I, the Commission may terminate the license. If alternatives are acceptable for reactor facility retirement. these levels are exceeded, the licensee retains the If minor disassembly or "mothballing" is planned, this possession-only license under which the dismantling could be done by the existing operating and mainte- activities have been conducted or, as an alternative, may nance procedures under the license in effect. Any make application to the State (if an Agreement State) planned actions involving an unreviewed safety question for a byproduct materials license.

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TABLE I a ACCEPTABLE SURFACE CONTAMINATION LEVELS REMOVABLEb e NUCLIDEa " AVERAGEb c MAXIMUMb d 2 2 2 U-nat, U-235, U-238, and 5,000 dpm a/100 cm 15,000 dpm a/ 100 cm 1,000 dpm a/100 cm associated decayqroducts 2

Transuranics, Ra-226, Ra-228, 100 dpm/lO0 cm 300 dpm/1O0 cm 2 20 dpm/100 cm 2 .

Th-230, Th-228, Pa-231, Ac-227, 1.125,1-129 2

Th-nat, Th-232, Sr-90, 1000 dpm/l O0 cm2 3000 dpm/100 cm 200 dpm/ l00 cm 2 Ra-223, Ra-224, U-232, 1-126,1-131,1-133 2 2 2 Beta-gamm emitters (nuclides 5000 dpm 0-y/100 cm 15,000 dpm 0-,/100 cm 1000 dpmr'7/100 cm with decay modes other than alpha emission or spontaneous fission) except St-90 and others noted above.

aWhere surface contamination. by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting nuclides should apply independently.

bA, used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appioprlate detector for background, efficiency, and geometric factors associated with the instrumentation-qteasurements of iverwe contaminant should not be averaged over more than 1 square mete.. For objects of less surface area, the average should be derived for each such object.

dThe maximum contamination level applies to an area of not more than 100 cm 2 .

The amount of removable radioactive material per 100 cm 2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of lesF surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.

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